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 claim in cash of differential duty - SCN was not issued - It is the basic tenet of our Constitution that “justice should not only be done, but should manifestly and undoubtedly be seen to be done” - The fundamental principles of law are at stake and the Orders have been passed without affording proper and reasonable opportunities to the appellant - Matter restored back - AT
Rejection of Refund claim in cash of differential duty - SCN was not issued - It is the basic tenet of our Constitution that “justice should not only be done, but should manifestly and undoubtedly be seen to be done” - The fundamental principles of law are at stake and the Orders have been passed without affording proper and reasonable opportunities to the appellant - Matter restored back - AT
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