Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Valuation - Denial of SSI exemption - Clubbing of clearance - It is not only that the manufacturing units and trading units are liable to be held as related persons as per Section 4 (3) (b) (iv), they are in effect one single large unit - the duty is required to be determined on the basis of the price on which the trading units have ultimately sold the goods to independent buyers. - AT
Valuation - Denial of SSI exemption - Clubbing of clearance - It is not only that the manufacturing units and trading units are liable to be held as related persons as per Section 4 (3) (b) (iv), they are in effect one single large unit - the duty is required to be determined on the basis of the price on which the trading units have ultimately sold the goods to independent buyers. - AT
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