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...
Reversal of CENVAT Credit - Capital Goods - Lease back of sold out capital goods - Deemed removal of goods from the factory premises of the petitioner - core contention of the petitioner's counsel is that the Central Excise Act does not contemplate any deemed removal - The order impugned in the writ petition is quashed. The matter is remitted to the file of the respondent. The respondent will bear in mind the Circular No. 1063/2/2018-CX - HC
Reversal of CENVAT Credit - Capital Goods - Lease back of sold out capital goods - Deemed removal of goods from the factory premises of the petitioner - core contention of the petitioner's counsel is that the Central Excise Act does not contemplate any deemed removal - The order impugned in the writ petition is quashed. The matter is remitted to the file of the respondent. The respondent will bear in mind the Circular No. 1063/2/2018-CX - HC
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