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...
Fraudulent availment of benefit of Duty Drawback - diversion of goods (exported) to third country or not - Revenue have not brought on record any evidence of diversion of goods to any third country - Admittedly, the goods have been exported by air from India to Russia and thus, chances to diversion to third country is highly impossible, without the goods first reaching Russia. - AT
Fraudulent availment of benefit of Duty Drawback - diversion of goods (exported) to third country or not - Revenue have not brought on record any evidence of diversion of goods to any third country - Admittedly, the goods have been exported by air from India to Russia and thus, chances to diversion to third country is highly impossible, without the goods first reaching Russia. - AT
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