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...
Additional depredation u/s 32 (1)(iia) - process of delivery of CNG to automobiles at the CNG filling centres - Fulfilment of mandate of manufacture or production - Compressed natural gas in its compressed form has a distinct identity and character and use - when a commodity acquires a distinct name, use and commercial identity, it would acquire the trait of 'manufacture' - AT
Additional depredation u/s 32 (1)(iia) - process of delivery of CNG to automobiles at the CNG filling centres - Fulfilment of mandate of manufacture or production - Compressed natural gas in its compressed form has a distinct identity and character and use - when a commodity acquires a distinct name, use and commercial identity, it would acquire the trait of 'manufacture' - AT
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