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 claim - mere admission of an appeal would not by itself lead to the stay of the order being appealed against before this Court, it only indicates that the issue raised in the appeal requires consideration and does not denying the benefits available to the respondents by virtue of the impugned order of the Tribunal - no stay for refund
Refund claim - mere admission of an appeal would not by itself lead to the stay of the order being appealed against before this Court, it only indicates that the issue raised in the appeal requires consideration and does not denying the benefits available to the respondents by virtue of the impugned order of the Tribunal - no stay for refund
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