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...
Recovery of amount refunded - Department did not file any appeal against the Order-in-Original granting refund to the appellant which has attained finality and cannot be offset by demand of refund on the ground that it is erroneous.
Recovery of amount refunded - Department did not file any appeal against the Order-in-Original granting refund to the appellant which has attained finality and cannot be offset by demand of refund on the ground that it is erroneous.
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