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...
Conversion of shipping bills from free to Advance License shipping bills - the request for conversion was to the schemes involving same level of examination and hence, the conversion of shipping bills are to be permitted as per Para 3 of Circular No. 36/2010. - the denial of benefit is clearly unacceptable and not in terms of the spirits of Section 149 - AT
Conversion of shipping bills from free to Advance License shipping bills - the request for conversion was to the schemes involving same level of examination and hence, the conversion of shipping bills are to be permitted as per Para 3 of Circular No. 36/2010. - the denial of benefit is clearly unacceptable and not in terms of the spirits of Section 149 - AT
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