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 on excess duty paid rejected as time bar - even though there is a clause in the agreement stipulating downward revision of prices, the same cannot be taken to be an assessment to duty on provisional basis - AT
Refund claim on excess duty paid rejected as time bar - even though there is a clause in the agreement stipulating downward revision of prices, the same cannot be taken to be an assessment to duty on provisional basis - AT
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