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...
Rejection of refund claim - appellant has not opted for provisional assessment - the refund claim cannot be rejected merely because an assessee had not opted for provisional assessment when there is excess payment of duty - the rejection of refund-claim alleging that the appellant has not opted for provisional assessment is not justified. - AT
Rejection of refund claim - appellant has not opted for provisional assessment - the refund claim cannot be rejected merely because an assessee had not opted for provisional assessment when there is excess payment of duty - the rejection of refund-claim alleging that the appellant has not opted for provisional assessment is not justified. - AT
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