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...
Cash Refund of the accumulated CENVAT credit - Reversal of credit migrated to GST (transitional credit) - In absence of any specific provision, subsequent debit under the IGST Act and rules made thereunder of the input tax credit, cannot be the circumstances to claim refund under Rule 5 of CENVAT Credit Rules, 2004 read with Notification No.27/2012-CE(NT). - AT
Cash Refund of the accumulated CENVAT credit - Reversal of credit migrated to GST (transitional credit) - In absence of any specific provision, subsequent debit under the IGST Act and rules made thereunder of the input tax credit, cannot be the circumstances to claim refund under Rule 5 of CENVAT Credit Rules, 2004 read with Notification No.27/2012-CE(NT). - AT
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