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 - inputs which were subsequently cleared “as such” to their sister unit without reversal of credit - a Revenue neutral situation - the appellant is a PSU, the extended period is not invokable
CENVAT Credit - inputs which were subsequently cleared “as such” to their sister unit without reversal of credit - a Revenue neutral situation - the appellant is a PSU, the extended period is not invokable
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