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 - Denial of refund of Terminal Excise Duty (TED) paid on the inputs - Since the Supreme Court has held that EOU is additionally eligible to avail of the entitlement of the DTA even though no duty was paid by them being ab initio exempt from payment of such duty subject to a suitable disclaimer from the DTA supplier and subject to compliance of other necessary formalities, in view of the change in law, the matter can be remanded to the concerned Commissioner for consideration. - HC
100% EOU - Denial of refund of Terminal Excise Duty (TED) paid on the inputs - Since the Supreme Court has held that EOU is additionally eligible to avail of the entitlement of the DTA even though no duty was paid by them being ab initio exempt from payment of such duty subject to a suitable disclaimer from the DTA supplier and subject to compliance of other necessary formalities, in view of the change in law, the matter can be remanded to the concerned Commissioner for consideration. - HC
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