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...
Redetermination of the assessable value of the goods imported - accepting the lowest of the contemporaneous import value of identically described goods - it is seen that all the doubts raised by the revenue were communicated to the appellant before the final decision was taken. - There are no error in the impugned order rejecting the declared value and accepting the lowest of the contemporaneous import value of identically described goods falling under the identical heading imported at roughly the same time - AT
Redetermination of the assessable value of the goods imported - accepting the lowest of the contemporaneous import value of identically described goods - it is seen that all the doubts raised by the revenue were communicated to the appellant before the final decision was taken. - There are no error in the impugned order rejecting the declared value and accepting the lowest of the contemporaneous import value of identically described goods falling under the identical heading imported at roughly the same time - AT
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