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 of unutilized cenvat credit - The Tribunal held that denial of refund on the grounds that the appellant did not possess registration and that the goods exported were exempted is not sustainable. It was established that even if manufactured goods/output services are exempted, the refund of Service Tax against export of the same cannot be denied. - AT
Refund claim of unutilized cenvat credit - The Tribunal held that denial of refund on the grounds that the appellant did not possess registration and that the goods exported were exempted is not sustainable. It was established that even if manufactured goods/output services are exempted, the refund of Service Tax against export of the same cannot be denied. - AT
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