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...
Waiver of penalty - Complete revenue neutrality is linked with the question of imposition of penalty - the duty is chargeable but it is 100% refundable, the question of intention to evade payment of duty pales into insignificance.
Waiver of penalty - Complete revenue neutrality is linked with the question of imposition of penalty - the duty is chargeable but it is 100% refundable, the question of intention to evade payment of duty pales into insignificance.
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