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...
Export of Finished Leather or Unfinished Leather - The fact of buyer accepting the goods and making payment, ordering further quantities and terming only 13 cartons of suede leather of grey colour as unfinished leather when 24 cartons of other colours of the same consignment as finished leather have weighed in our mind. - minor deficiency in the processing may not ipso facto make the leather as not fully finished as the appellant’s have carried out all the major operations. - AT
Export of Finished Leather or Unfinished Leather - The fact of buyer accepting the goods and making payment, ordering further quantities and terming only 13 cartons of suede leather of grey colour as unfinished leather when 24 cartons of other colours of the same consignment as finished leather have weighed in our mind. - minor deficiency in the processing may not ipso facto make the leather as not fully finished as the appellant’s have carried out all the major operations. - AT
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