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...
Refund of Excess ITR certified by the Auditor - Input Tax Rebate (ITR) - u/s 15, the burden of proving that any sale or purchase effected by a dealer is not liable to tax under Section 9 or Section 10 as the case may be, or that he is eligible for an input tax rebate under Section 14 shall be on the dealer, therefore, the burden was on the appellant to satisfy that the Input Tax Rebate for which he claimed the rebate was duly paid by the selling dealer before the sale of the goods. The authorities have recorded the satisfaction that those selling dealers did not show these sales to the appellant in their VAT Tax Return. - HC
Refund of Excess ITR certified by the Auditor - Input Tax Rebate (ITR) - u/s 15, the burden of proving that any sale or purchase effected by a dealer is not liable to tax under Section 9 or Section 10 as the case may be, or that he is eligible for an input tax rebate under Section 14 shall be on the dealer, therefore, the burden was on the appellant to satisfy that the Input Tax Rebate for which he claimed the rebate was duly paid by the selling dealer before the sale of the goods. The authorities have recorded the satisfaction that those selling dealers did not show these sales to the appellant in their VAT Tax Return. - HC
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