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...
CENVAT Credit - input services - legal services - denial on account of nexus - these services were in relation to acquisition of the new plants and investments which have no nexus whatsoever with the manufacture by any of their plants. These facts are not in dispute - credit denied.
CENVAT Credit - input services - legal services - denial on account of nexus - these services were in relation to acquisition of the new plants and investments which have no nexus whatsoever with the manufacture by any of their plants. These facts are not in dispute - credit denied.
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