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...
Rebate claim - export of services - denied on the ground that services rendered within India - the supply had been effected to a Special Economic Zone and a recipient operating, or in, a Special Economic Zone is entitled to tax exemption that devolves upon the provider - the appellant was entitle to the refund/rebate of the taxes paid on the services
Rebate claim - export of services - denied on the ground that services rendered within India - the supply had been effected to a Special Economic Zone and a recipient operating, or in, a Special Economic Zone is entitled to tax exemption that devolves upon the provider - the appellant was entitle to the refund/rebate of the taxes paid on the services
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