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 - unjust enrichment - Cost Accountant’s certificates do not specify any records or books of account which were claimed to have been verified at his end. - claim of refund rejected - AT
Refund - unjust enrichment - Cost Accountant’s certificates do not specify any records or books of account which were claimed to have been verified at his end. - claim of refund rejected - AT
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