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...
Levy of penalty - fraudulent passing of CENVAT Credit - Since the appellant’s case falls under Rule 26 (2) (ii) but the same is not existing at the relevant time the appellant cannot be penalized when the goods dealt with by him was not liable for confiscation on the ground that the same was admittedly duty paid. - AT
Levy of penalty - fraudulent passing of CENVAT Credit - Since the appellant’s case falls under Rule 26 (2) (ii) but the same is not existing at the relevant time the appellant cannot be penalized when the goods dealt with by him was not liable for confiscation on the ground that the same was admittedly duty paid. - AT
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