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 of Customs Duty paid in excess - denial of refund on the ground that the assessment had become final, there being no challenge to such assessment - considering the FOB price as cum-duty price, refund allowed.
Refund of Customs Duty paid in excess - denial of refund on the ground that the assessment had become final, there being no challenge to such assessment - considering the FOB price as cum-duty price, refund allowed.
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