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 customs duty - it is clear that the refund claim is not filed within the time prescribed for the same. Commissioner (Appeals) is therefore held to have rightly upheld the claim as being barred by time. - AT
Refund of customs duty - it is clear that the refund claim is not filed within the time prescribed for the same. Commissioner (Appeals) is therefore held to have rightly upheld the claim as being barred by time. - AT
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