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...
Valuation - crank cases - job-work activity or not - Any amount of supervision per se, may not be sufficient to treat the assessee-appellant as a job worker - there are no merit in the impugned orders on the merits as well as on the principles of consistency and consequently, the same are set aside. - AT
Valuation - crank cases - job-work activity or not - Any amount of supervision per se, may not be sufficient to treat the assessee-appellant as a job worker - there are no merit in the impugned orders on the merits as well as on the principles of consistency and consequently, the same are set aside. - AT
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