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...
Classification of imported goods - change in the stand of revenue during the appellate proceedings - The approach of the Revenue who have chosen to file the present appeal for the reasons that as and when the Order-in-Original was received, they slept over the matter and thus missed the bus. Secondly, having not exhausted the available opportunity, they have contended that the Commissioner (Appeals) should have, on his own, exercised power under Section 128A (3) which, according to us, does not stand - AT
Classification of imported goods - change in the stand of revenue during the appellate proceedings - The approach of the Revenue who have chosen to file the present appeal for the reasons that as and when the Order-in-Original was received, they slept over the matter and thus missed the bus. Secondly, having not exhausted the available opportunity, they have contended that the Commissioner (Appeals) should have, on his own, exercised power under Section 128A (3) which, according to us, does not stand - AT
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