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...
100% EOU - refund of unutilized balance of cesses in cash - CGST Act does not allow them to carry forward the cesses as input tax credit - There is no provision in the CENVAT Credit Rules 2004 or the Central Excise Act 1944 to allow cash refund of cesses lying in balance in the CENVAT Credit account on the ground that appellant was not able to use the same. - AT
100% EOU - refund of unutilized balance of cesses in cash - CGST Act does not allow them to carry forward the cesses as input tax credit - There is no provision in the CENVAT Credit Rules 2004 or the Central Excise Act 1944 to allow cash refund of cesses lying in balance in the CENVAT Credit account on the ground that appellant was not able to use the same. - AT
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