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...
Demand of interest - advance received earlier, returned by the appellant later - The demand of interest on the advance (of Rs.85 crores) received by the appellant and returned thereafter, as confirmed in paragraph 14.1 of the impugned order, cannot sustain and requires to be set aside - AT
Demand of interest - advance received earlier, returned by the appellant later - The demand of interest on the advance (of Rs.85 crores) received by the appellant and returned thereafter, as confirmed in paragraph 14.1 of the impugned order, cannot sustain and requires to be set aside - AT
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