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...
Rejection of request of the IOC for conversion of DEEC Shipping Bills to Drawback Scheme - Delay between 6 months to 1 year - Period of limitation - If the request / application seeking conversion is made within a specified period, it would enable the department to verify the claim diligently and promptly as also the availability of the documents. - The appeal filed by the Appellant was barred by time and was rightly rejected by the competent authority - AT
Rejection of request of the IOC for conversion of DEEC Shipping Bills to Drawback Scheme - Delay between 6 months to 1 year - Period of limitation - If the request / application seeking conversion is made within a specified period, it would enable the department to verify the claim diligently and promptly as also the availability of the documents. - The appeal filed by the Appellant was barred by time and was rightly rejected by the competent authority - AT
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