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...
Refund claim - Unjust Enrichment - Since in the case in hand, the respondent herein had furnished declarations from the parties/group companies/sister concerns to whom allegedly the incidence of duty is passed on, refund is to be allowed - refund allowed.
Refund claim - Unjust Enrichment - Since in the case in hand, the respondent herein had furnished declarations from the parties/group companies/sister concerns to whom allegedly the incidence of duty is passed on, refund is to be allowed - refund allowed.
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