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 - Capital Goods - allegation that plant erected at site are embedded to the earth and as such, such plant facilities cannot be considered as excisable goods for the purpose of availment of CENVAT credit on such disputed items - The denial of CENVAT benefit on the disputed goods should not stand for judicial scrutiny, as against rules framed in the CENVAT Statute - AT
CENVAT credit - Capital Goods - allegation that plant erected at site are embedded to the earth and as such, such plant facilities cannot be considered as excisable goods for the purpose of availment of CENVAT credit on such disputed items - The denial of CENVAT benefit on the disputed goods should not stand for judicial scrutiny, as against rules framed in the CENVAT Statute - AT
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