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...
Extended period of limitation – input service – denial of Cenvat credit - the term 'Used' cannot cover the definition of input service, it would be purely a question of interpretation and therefore, show cause notice could not have been issued invoking extended period. - AT
Extended period of limitation – input service – denial of Cenvat credit - the term 'Used' cannot cover the definition of input service, it would be purely a question of interpretation and therefore, show cause notice could not have been issued invoking extended period. - AT
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