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 - rejection of declared value - import of Synthetic Rubber PBR Non Oil Off Grade Loose Lumps in Super Sacks Packing - The Department has failed to show any contemporaneous evidence of higher price, and thus the transaction value cannot be rejected
Valuation - rejection of declared value - import of Synthetic Rubber PBR Non Oil Off Grade Loose Lumps in Super Sacks Packing - The Department has failed to show any contemporaneous evidence of higher price, and thus the transaction value cannot be rejected
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