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 accumulated Cenvat credit - failure to submit documentary evidence for export of services - The fact of export of such software and the receipt of the foreign exchange therefore is sufficiently evidenced from the invoices, the FIRCs and the Chartered Accountant’s certificate certifying the total turnover.
Refund of accumulated Cenvat credit - failure to submit documentary evidence for export of services - The fact of export of such software and the receipt of the foreign exchange therefore is sufficiently evidenced from the invoices, the FIRCs and the Chartered Accountant’s certificate certifying the total turnover.
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