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...
Admissibility of appeals - grant of ITC - merely because certain documents may have been brought on record may not itself be sufficient to grant ITC - once claim had been rejected by the AO, the appellate authority was obliged to record a positive finding after due appraisal of the evidence on record or calling remand report - failure leads to order erroneous and are premature - remanded
Admissibility of appeals - grant of ITC - merely because certain documents may have been brought on record may not itself be sufficient to grant ITC - once claim had been rejected by the AO, the appellate authority was obliged to record a positive finding after due appraisal of the evidence on record or calling remand report - failure leads to order erroneous and are premature - remanded
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