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...
Rejection of refund - Pre-deposit or receivable - principles of unjust enrichment - On the one hand, the appellant claims that the amount paid is to be treated as pre-deposit for which unjust enrichment would not apply, but, on the other hand, fails to furnish the necessary documents requested by the authorities who are empowered to look into all aspects before passing an order. - AT
Rejection of refund - Pre-deposit or receivable - principles of unjust enrichment - On the one hand, the appellant claims that the amount paid is to be treated as pre-deposit for which unjust enrichment would not apply, but, on the other hand, fails to furnish the necessary documents requested by the authorities who are empowered to look into all aspects before passing an order. - AT
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