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 - slag - exempt goods - Board’s Circular which has been issued without taking into consideration the implications of the provisions and the instructions, cannot be applied blindly for drawing adverse conclusion against the assessee. It was also held that merely on the strength of the said Circular dated 14.01.2011 Cenvat Credit cannot be denied, when there is no such provision in the Cenvat Credit Rules, 2004. - AT
CENVAT Credit - slag - exempt goods - Board’s Circular which has been issued without taking into consideration the implications of the provisions and the instructions, cannot be applied blindly for drawing adverse conclusion against the assessee. It was also held that merely on the strength of the said Circular dated 14.01.2011 Cenvat Credit cannot be denied, when there is no such provision in the Cenvat Credit Rules, 2004. - AT
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