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...
Levy of interest and penalty - Reversal of CENVAT Credit (without utilization) on being pointed out, before issuance of SCN - period from January, 2005 to March, 2007 - the interest is chargeable in event of either wrongly availed credit or wrongly utilized. Therefore, even though the credit was not utilized but since the credit was wrongly availed the interest is unavoidably chargeable. - AT
Levy of interest and penalty - Reversal of CENVAT Credit (without utilization) on being pointed out, before issuance of SCN - period from January, 2005 to March, 2007 - the interest is chargeable in event of either wrongly availed credit or wrongly utilized. Therefore, even though the credit was not utilized but since the credit was wrongly availed the interest is unavoidably chargeable. - AT
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