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...
Refund of excess duty paid - Valuation - sales made to their dealers (customers) who in turn sell the final product - orders of finalizing the provisional assessment were never challenged before the higher authorities and have attained finality - doctrine of unjust enrichment is not applicable in the case of provisional assessment - refund allowed.
Refund of excess duty paid - Valuation - sales made to their dealers (customers) who in turn sell the final product - orders of finalizing the provisional assessment were never challenged before the higher authorities and have attained finality - doctrine of unjust enrichment is not applicable in the case of provisional assessment - refund allowed.
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