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...
Penultimate sale - leather garments - The mere claim of the Assessee that the Assessing Authority had initially allowed such exemption u/s 5(3) of the Act upon due scrutiny of the transactions is not acceptable, because the finding of facts with regard to inextricable link between the sale or purchase claimed to be exempted u/s 5(3) of the Act and the export has to be established by the Assessee by leading evidence - Matter restored back - HC
Penultimate sale - leather garments - The mere claim of the Assessee that the Assessing Authority had initially allowed such exemption u/s 5(3) of the Act upon due scrutiny of the transactions is not acceptable, because the finding of facts with regard to inextricable link between the sale or purchase claimed to be exempted u/s 5(3) of the Act and the export has to be established by the Assessee by leading evidence - Matter restored back - HC
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