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 claim - Deemed export - Period of limitation - intermediate goods are cleared to another EOU - The relevant date needs to be considered from the end of the quarter - the refund claims for the quarters January 2010 to March 2010, April 2010 to June 2010 and July 2010 to September 2010 are admissible to the appellant whereas the refund claim for the quarter October 2009 to December 2009 is hit by limitation. - AT
Refund claim - Deemed export - Period of limitation - intermediate goods are cleared to another EOU - The relevant date needs to be considered from the end of the quarter - the refund claims for the quarters January 2010 to March 2010, April 2010 to June 2010 and July 2010 to September 2010 are admissible to the appellant whereas the refund claim for the quarter October 2009 to December 2009 is hit by limitation. - AT
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