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...
Maintainability of petition - Validity of Rule 17(2) of the Pan Masala Packing Machines (Capacity, Determination and Collection of Duty) Rules, 2008 - The reason that the pre-deposit being burdensome does not appeal to us - The challenge to the vires of Rule 17(2) of the Pan Masala Rules is rather without substance and therefore we do not consider it necessary to deal with the same in this case. - HC
Maintainability of petition - Validity of Rule 17(2) of the Pan Masala Packing Machines (Capacity, Determination and Collection of Duty) Rules, 2008 - The reason that the pre-deposit being burdensome does not appeal to us - The challenge to the vires of Rule 17(2) of the Pan Masala Rules is rather without substance and therefore we do not consider it necessary to deal with the same in this case. - HC
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