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...
Interest on delayed Refund of excess Customs Duty paid - Evidently, the Learned Commissioner has taken the date of receipt of Final Order of the Tribunal as the relevant date for calculation of interest to be paid on the refunded amount. This is clearly contrary to the provisions of Section 27A which has only one date for calculation of interest which is the date of refund application. - AT
Interest on delayed Refund of excess Customs Duty paid - Evidently, the Learned Commissioner has taken the date of receipt of Final Order of the Tribunal as the relevant date for calculation of interest to be paid on the refunded amount. This is clearly contrary to the provisions of Section 27A which has only one date for calculation of interest which is the date of refund application. - AT
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