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...
Re-valuation of the impugned goods imported - It is the settled position of law that NIDB data cannot be the only basis for rejection of the declared value - The Revenue has not made out a case firstly, for the rejection of the declared value and secondly, no case is either made out justifying re-determination of the same. - AT
Re-valuation of the impugned goods imported - It is the settled position of law that NIDB data cannot be the only basis for rejection of the declared value - The Revenue has not made out a case firstly, for the rejection of the declared value and secondly, no case is either made out justifying re-determination of the same. - AT
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