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 - credit on inputs lying in stock, work in progress and finished goods as on the date of rescinding of the exemption notification in terms of sub-rule 2 (3) of CCR, 2004 - The appellants have though not made out a case on merits of the issue, have certainly made out a strong case in their favour on limitation and succeed on this count - SCN is time barred - AT
CENVAT Credit - credit on inputs lying in stock, work in progress and finished goods as on the date of rescinding of the exemption notification in terms of sub-rule 2 (3) of CCR, 2004 - The appellants have though not made out a case on merits of the issue, have certainly made out a strong case in their favour on limitation and succeed on this count - SCN is time barred - AT
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