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...
Job-work - failure on the part of principal to pay the duty - appellant have not availed the benefit of N/N. 10/97-CE, which was availed by the principal manufacturer and, therefore, the demand of duty for violation of the terms of N/N. 10/97-CE cannot be raised against the appellant
Job-work - failure on the part of principal to pay the duty - appellant have not availed the benefit of N/N. 10/97-CE, which was availed by the principal manufacturer and, therefore, the demand of duty for violation of the terms of N/N. 10/97-CE cannot be raised against the appellant
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