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 - use of intermediate goods (Neutral Filter Cake) as inputs - engaged in the production of dutiable as well as exempted product - the finding of fact that the input used is only minimal(1%) is not controverted - it is also beyond controversy that the said input has been treated as a separate final product and the duty thereon has been paid adjusting the duty paid as input - input allowable
CENVAT Credit - use of intermediate goods (Neutral Filter Cake) as inputs - engaged in the production of dutiable as well as exempted product - the finding of fact that the input used is only minimal(1%) is not controverted - it is also beyond controversy that the said input has been treated as a separate final product and the duty thereon has been paid adjusting the duty paid as input - input allowable
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