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...
Remission of central excise duty on semi-finished goods destroyed in the fire accident - The Commissioner clearly exceeded his jurisdiction in deciding this issue by going beyond the terms of the remand order passed by the Tribunal as all that was required to be determined by the Commissioner on remand was to verify whether the element of excise duty involved in the goods destroyed by the fire accident was paid by insurance company or not. This issue has now been decided in favour of the appellant by the Commissioner. - Benefit of remission allowed - AT
Remission of central excise duty on semi-finished goods destroyed in the fire accident - The Commissioner clearly exceeded his jurisdiction in deciding this issue by going beyond the terms of the remand order passed by the Tribunal as all that was required to be determined by the Commissioner on remand was to verify whether the element of excise duty involved in the goods destroyed by the fire accident was paid by insurance company or not. This issue has now been decided in favour of the appellant by the Commissioner. - Benefit of remission allowed - AT
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