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...
Duty drawback - Re-fixation of brand rates - the Revisional Authority was under a duty to scrutinize this aspect carefully. Except referring to the language of the Circular dated 18 September 2003, the Revisional Authority has not examined whether any amendment, addendum or corrigendum was carried out or that order existed even what is stated in clause 3(c) of the Circular dated 18 September 2003. - Matter restored back - HC
Duty drawback - Re-fixation of brand rates - the Revisional Authority was under a duty to scrutinize this aspect carefully. Except referring to the language of the Circular dated 18 September 2003, the Revisional Authority has not examined whether any amendment, addendum or corrigendum was carried out or that order existed even what is stated in clause 3(c) of the Circular dated 18 September 2003. - Matter restored back - HC
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