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...
Seeking provisional release of the export consignment - Once the reasoned order for provisional released has been passed in respect of the relevant consignment under the provisions of section 110A of the said Act and the conditions for such provisional release have been complied with by the applicant/petitioner, we fail to comprehend as to how such an administrative order could be cited as a precedent in future cases so as to preclude us from making an order as prayed for in the interim application. - HC
Seeking provisional release of the export consignment - Once the reasoned order for provisional released has been passed in respect of the relevant consignment under the provisions of section 110A of the said Act and the conditions for such provisional release have been complied with by the applicant/petitioner, we fail to comprehend as to how such an administrative order could be cited as a precedent in future cases so as to preclude us from making an order as prayed for in the interim application. - HC
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