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 claim - unjust enrichment - Once evidence is produced by the respondent that they have borne the incidence of duty whose refund is claimed by them, the burden would shift to the department to prove that the respondent’s claim is not correct. - AT
Refund claim - unjust enrichment - Once evidence is produced by the respondent that they have borne the incidence of duty whose refund is claimed by them, the burden would shift to the department to prove that the respondent’s claim is not correct. - AT
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