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 penalty Rule 26 of Central Excise Act, 2002 - charge of abatement in the offence of fraudulent availment of cenvat credit - All the appellant having direct and active role in entire modus operandi of wrong availment of cenvat credit by the manufacturer - Therefore, the penalties imposed on the appellant is correct hence, the same is upheld. - AT
Levy of penalty Rule 26 of Central Excise Act, 2002 - charge of abatement in the offence of fraudulent availment of cenvat credit - All the appellant having direct and active role in entire modus operandi of wrong availment of cenvat credit by the manufacturer - Therefore, the penalties imposed on the appellant is correct hence, the same is upheld. - AT
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