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 - when two lower adjudicating authorities had come to a finding on facts that the assessee was not entitled to Cenvat Credit on inputs, there was a higher burden on the Tribunal to consider all the facts and evidence in the records and come to a reasonable finding - reversal of the said findings without more reasons gives rise to a substantial question of law
CENVAT Credit - when two lower adjudicating authorities had come to a finding on facts that the assessee was not entitled to Cenvat Credit on inputs, there was a higher burden on the Tribunal to consider all the facts and evidence in the records and come to a reasonable finding - reversal of the said findings without more reasons gives rise to a substantial question of law
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