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 removal - double jeopardy - Both the show cause notices have alleged different offences to have been committed by the appellants, which are punishable under different provisions of the law - Penalty for both the show cause notices irrespective that they are arising out of the same transaction of acts cannot be called as double jeopardy.
Clandestine removal - double jeopardy - Both the show cause notices have alleged different offences to have been committed by the appellants, which are punishable under different provisions of the law - Penalty for both the show cause notices irrespective that they are arising out of the same transaction of acts cannot be called as double jeopardy.
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