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...
Exemption under PTA Notification - Admittedly the appellant never claimed the benefit of the Notification in which case the question of denial of the same cannot arise and it can be safely concluded that there was no ‘lis’ between the importer and the Revenue - Benefit allowed.
Exemption under PTA Notification - Admittedly the appellant never claimed the benefit of the Notification in which case the question of denial of the same cannot arise and it can be safely concluded that there was no ‘lis’ between the importer and the Revenue - Benefit allowed.
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