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...
SSI Exemption - clubbing of clearances - Two independent companies within same complex (factory premises) and common shareholders / directors / management - The clearance of the appellant unit and M/s. NAPL cannot be clubbed. If the clearances of the appellant are to be clubbed with M/s.NAPL then the duty is required to be demanded from M/s.NAPL, which is not the case here
SSI Exemption - clubbing of clearances - Two independent companies within same complex (factory premises) and common shareholders / directors / management - The clearance of the appellant unit and M/s. NAPL cannot be clubbed. If the clearances of the appellant are to be clubbed with M/s.NAPL then the duty is required to be demanded from M/s.NAPL, which is not the case here
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