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...
Exemption from the whole of the duty of customs - Import of Machinery as Gift - bilateral Agreement - This factual portion is also reflected from the Certificate dated 09.11.1999 given by the European Union. The Certificate clearly mentions that the plant and machinery was gifted free of cost to the Programme under the bilateral Agreement between the Government of India and the European Union - On a plain reading of the Agreement, it is clear that clause 8 of the exemption notification stands satisfied - AT
Exemption from the whole of the duty of customs - Import of Machinery as Gift - bilateral Agreement - This factual portion is also reflected from the Certificate dated 09.11.1999 given by the European Union. The Certificate clearly mentions that the plant and machinery was gifted free of cost to the Programme under the bilateral Agreement between the Government of India and the European Union - On a plain reading of the Agreement, it is clear that clause 8 of the exemption notification stands satisfied - AT
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