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...
Lesser sanction of refund claim and non-payment of interest - The department was required to sanction the amount as claimed in the original refund application, which was rejected by the original authority, but the Appeal of the Appellant was ultimately allowed by the Tribunal. The department is directed to refund the amount, as claimed in the original refund application filed by the respective Appellants. - Interest also directed to be paid - AT
Lesser sanction of refund claim and non-payment of interest - The department was required to sanction the amount as claimed in the original refund application, which was rejected by the original authority, but the Appeal of the Appellant was ultimately allowed by the Tribunal. The department is directed to refund the amount, as claimed in the original refund application filed by the respective Appellants. - Interest also directed to be paid - AT
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