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 rejected as time bar - The original authority and the lower appellate authority being creatures of the statute, prima facie are required to follow the statutory provisions - AT
Refund claim rejected as time bar - The original authority and the lower appellate authority being creatures of the statute, prima facie are required to follow the statutory provisions - AT
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