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...
Cenvat credit - Bill of Entry in the name of the supplier of the raw material i.e. Principal - goods were received by the appellant as a job worker and used in the manufacture of goods on the job work basis - appellant is entitled for Cenvat credit on the strength of Bill of Entry even though the same is in the name of Principal but with a declaration in favour of the appellant. - AT
Cenvat credit - Bill of Entry in the name of the supplier of the raw material i.e. Principal - goods were received by the appellant as a job worker and used in the manufacture of goods on the job work basis - appellant is entitled for Cenvat credit on the strength of Bill of Entry even though the same is in the name of Principal but with a declaration in favour of the appellant. - AT
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