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 - availing 50% credit on capital goods after absolute exemption - Restriction of availment of 50% in the first financial year and the balance subsequently, is only a procedural compulsion brought about by sub-ordinate legislation. However that cannot take away the right of availment of credit that is vested with the appellant at the time when goods were received in the factory.
CENVAT Credit - availing 50% credit on capital goods after absolute exemption - Restriction of availment of 50% in the first financial year and the balance subsequently, is only a procedural compulsion brought about by sub-ordinate legislation. However that cannot take away the right of availment of credit that is vested with the appellant at the time when goods were received in the factory.
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