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...
Service of order - revenue can not take the shelter of provisions of Section 37C of the Central Excise Act as these provisions are only for the Department - AT
Service of order - revenue can not take the shelter of provisions of Section 37C of the Central Excise Act as these provisions are only for the Department - AT
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