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...
Rebate claim - Relevant Date - The period of limitation of one year commences from the Relevant Date. The relevant date as defined in Explanation (B) to this provision, states that for the purposes of goods exported by sea, is the date on which ship in which goods are loaded, leaves India. Thereafter the relevant date for other contingencies has been enumerated and Clause (f), the residuary clause states that in any other case, the relevant date will be the date of payment of duty. - HC
Rebate claim - Relevant Date - The period of limitation of one year commences from the Relevant Date. The relevant date as defined in Explanation (B) to this provision, states that for the purposes of goods exported by sea, is the date on which ship in which goods are loaded, leaves India. Thereafter the relevant date for other contingencies has been enumerated and Clause (f), the residuary clause states that in any other case, the relevant date will be the date of payment of duty. - HC
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