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...
Clandestine Removal - mild steel ingots from sponge iron - pig iron - There is no explanation forthcoming in the impugned orders for discarding of the energy consumption determined during the trial production except to cast doubts by relying upon reports that, admittedly, did not test the furnace deployed by the appellant-assessee - the singular continuity of adjudicatory evaluation from the earlier period, discarded by the Tribunal in the appeal of the very same assessee and individual, to the present demand, the impugned order is bereft of sufficient facts and evidence to be sustained in appellate proceeding. - AT
Clandestine Removal - mild steel ingots from sponge iron - pig iron - There is no explanation forthcoming in the impugned orders for discarding of the energy consumption determined during the trial production except to cast doubts by relying upon reports that, admittedly, did not test the furnace deployed by the appellant-assessee - the singular continuity of adjudicatory evaluation from the earlier period, discarded by the Tribunal in the appeal of the very same assessee and individual, to the present demand, the impugned order is bereft of sufficient facts and evidence to be sustained in appellate proceeding. - AT
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