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...
Clandestine removal - allegation to avail the benefit of area based exemption(Rookee unit) wrongly - demand is being confirmed against Ghaziabad unit, without producing any evidence even no discrepancy was found in enquiry - It is well settled law that the findings of clandestine removal are required to be established on the basis of positive and sufficient evidences - demand canceled
Clandestine removal - allegation to avail the benefit of area based exemption(Rookee unit) wrongly - demand is being confirmed against Ghaziabad unit, without producing any evidence even no discrepancy was found in enquiry - It is well settled law that the findings of clandestine removal are required to be established on the basis of positive and sufficient evidences - demand canceled
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