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...
Denial of Duty Free Credit Entitlement [DFCE] Certificate to the petitioner - The dispute is as to whether the petitioner was status holder or a Star Export House. The said question is answered by the order of the very Department made on 16.06.2006 wherein the petitioner has been recognized as a Star Export House as on 01.04.2003. Therefore, it is clear that the petitioner had satisfied the requirements of the amended provisions of the scheme. - HC
Denial of Duty Free Credit Entitlement [DFCE] Certificate to the petitioner - The dispute is as to whether the petitioner was status holder or a Star Export House. The said question is answered by the order of the very Department made on 16.06.2006 wherein the petitioner has been recognized as a Star Export House as on 01.04.2003. Therefore, it is clear that the petitioner had satisfied the requirements of the amended provisions of the scheme. - HC
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