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...
CENVAT Credit - inputs - Wash Oil and Sulphuric Acid which were used directly or indirectly, in or in relation to the manufacture of coal Gas - The manufacturing process adopted by the assessee and the emergence of crude coke oven gas is technological necessity and in evitable by-product and it is not exempted final product and it is neither the case of the department that it is the final product - no part of input credit availed was to be disallowed. - HC
CENVAT Credit - inputs - Wash Oil and Sulphuric Acid which were used directly or indirectly, in or in relation to the manufacture of coal Gas - The manufacturing process adopted by the assessee and the emergence of crude coke oven gas is technological necessity and in evitable by-product and it is not exempted final product and it is neither the case of the department that it is the final product - no part of input credit availed was to be disallowed. - HC
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