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 - The said order dated 8.9.2014 was received by the petitioner on 29.9.2014 - Therefore, within one year therefrom, the refund claim was made on 9.9.2015. Though the actual date of application is 8.8.2015 but the receipt stamp indicates the date of 9.9.2015 and accordingly, it was said to have filed within the time limit prescribed.
Refund - The said order dated 8.9.2014 was received by the petitioner on 29.9.2014 - Therefore, within one year therefrom, the refund claim was made on 9.9.2015. Though the actual date of application is 8.8.2015 but the receipt stamp indicates the date of 9.9.2015 and accordingly, it was said to have filed within the time limit prescribed.
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