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 - appellant was acting in dual capacity i.e. as manufacturer and also service provider - Merely because the appellant themselves are the paint manufacturers and raised invoices in their own name but for HPCL site, they cannot be denied the Cenvat credit of duty paid by them.
CENVAT Credit - appellant was acting in dual capacity i.e. as manufacturer and also service provider - Merely because the appellant themselves are the paint manufacturers and raised invoices in their own name but for HPCL site, they cannot be denied the Cenvat credit of duty paid by them.
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