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...
Clandestine manufacture and removal - The allegation/observation of suppression of production and clandestine removal is a serious allegation and it has to be established by the investigation by affirmative and cogent evidence, which is absent in the Order –in-original except relying upon such documents and entries there in, which has been disputed by the Appellant - Demand set aside.
Clandestine manufacture and removal - The allegation/observation of suppression of production and clandestine removal is a serious allegation and it has to be established by the investigation by affirmative and cogent evidence, which is absent in the Order –in-original except relying upon such documents and entries there in, which has been disputed by the Appellant - Demand set aside.
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