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...
Refund claim of Additional Customs Duty (ACD) - rejection on the ground that as per correlation sheet, the description in Bill-of-Entry and invoices did not tally and the last digit in the Bill-of-Entry No. 9252028 was entered as “3” instead of “8” - inadvertent mistake - matter remanded back for fresh consideration - AT
Refund claim of Additional Customs Duty (ACD) - rejection on the ground that as per correlation sheet, the description in Bill-of-Entry and invoices did not tally and the last digit in the Bill-of-Entry No. 9252028 was entered as “3” instead of “8” - inadvertent mistake - matter remanded back for fresh consideration - AT
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