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...
Extended period of limitation - Reversal of CENVAT Credit - It is well settled law that onus is on the Department to prove that extended period of limitation is invokable by adducing evidence. In the present case, no such evidence has been adduced by the Department. - AT
Extended period of limitation - Reversal of CENVAT Credit - It is well settled law that onus is on the Department to prove that extended period of limitation is invokable by adducing evidence. In the present case, no such evidence has been adduced by the Department. - AT
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