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 became due on final assessment is to be made without the claim being submitted by the assessee and that the provisions of unjust enrichment are not applicable. - AT
Refund became due on final assessment is to be made without the claim being submitted by the assessee and that the provisions of unjust enrichment are not applicable. - AT
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