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...
Interest on unutilized reversed credit entry - The erstwhile Rule 14 of the Cenvat Credit Rules read as “taken or utilised”, which had been amended and substituted by the words “taken and utilised” - substantive benefit cannot be denied to the appellant - Demand of interest waived.
Interest on unutilized reversed credit entry - The erstwhile Rule 14 of the Cenvat Credit Rules read as “taken or utilised”, which had been amended and substituted by the words “taken and utilised” - substantive benefit cannot be denied to the appellant - Demand of interest waived.
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