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...
Interest on delayed refund - relevant date - order under challenge has wrongly restricted the entitlement of appellant for the interest on the refunded amount to the date w.e.f. the date of filing of appeal. The appellant in view of settled principles is held entitled for the interest on the refunded amount of Rs.50.00 Lakhs from the date of the respective deposit - AT
Interest on delayed refund - relevant date - order under challenge has wrongly restricted the entitlement of appellant for the interest on the refunded amount to the date w.e.f. the date of filing of appeal. The appellant in view of settled principles is held entitled for the interest on the refunded amount of Rs.50.00 Lakhs from the date of the respective deposit - AT
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