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...
Advance licenses - who is liable to fulfill the condition of notification, the original licensee or the “transferee” of the licensee? - Any way onus to prove that input stage credit was not availed in respect of the goods exported is not certainly on the “transferee” the licence i.e. appellants.
Advance licenses - who is liable to fulfill the condition of notification, the original licensee or the “transferee” of the licensee? - Any way onus to prove that input stage credit was not availed in respect of the goods exported is not certainly on the “transferee” the licence i.e. appellants.
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