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...
Valuation - Whether the appellant would be eligible for exemption N/N. 12/2003- ST? - The appellant had produced only documents to show that they have purchased materials but nothing to show that they have used the same in execution of the contracts - Matter remanded back.
Valuation - Whether the appellant would be eligible for exemption N/N. 12/2003- ST? - The appellant had produced only documents to show that they have purchased materials but nothing to show that they have used the same in execution of the contracts - Matter remanded back.
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