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...
100% EOU - calculation of Central Excise duty and Customs duty on the depreciated value of the capital goods - the CBEC circular is an administrative order binding on the departmental officer but it cannot prevail over on delegated legislation in the form of an exemption notification. When the notification itself has allowed depreciation for the entire quarter the circular cannot restrict it to part of it. - AT
100% EOU - calculation of Central Excise duty and Customs duty on the depreciated value of the capital goods - the CBEC circular is an administrative order binding on the departmental officer but it cannot prevail over on delegated legislation in the form of an exemption notification. When the notification itself has allowed depreciation for the entire quarter the circular cannot restrict it to part of it. - AT
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