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 in respect of unutilised Input Tax Credit (ITC) - time limitation - The appellate authority concluded that the refund claim can only be made with regard to a specific calendar month. This conclusion is contrary both to statutory prescription and Circular No.37. - the refund claim is within the time limit specified by statute that the petitioner is entitled to refund. - HC
Refund in respect of unutilised Input Tax Credit (ITC) - time limitation - The appellate authority concluded that the refund claim can only be made with regard to a specific calendar month. This conclusion is contrary both to statutory prescription and Circular No.37. - the refund claim is within the time limit specified by statute that the petitioner is entitled to refund. - HC
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