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 refund of unutilized credit - Export - Development of Computer Software - In the present case, the availment of credit is not contested by the Revenue and the appellants having exported the services cannot be disentitled to refund under Rule 5 on the ground that the exported services are exempt - AT
Seeking refund of unutilized credit - Export - Development of Computer Software - In the present case, the availment of credit is not contested by the Revenue and the appellants having exported the services cannot be disentitled to refund under Rule 5 on the ground that the exported services are exempt - AT
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