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...
Reversal of proportionate CENVAT credit - generation of electricity - CENVAT credit of Counterveiling Duty (CVD) on import of Coal - quantum of power wheeled out to sister units - The High Court held that the appellant is entitled to CENVAT credit for the electricity generated, even if wheeled out to sister units, as long as it is used within the company and not sold for consideration.
Reversal of proportionate CENVAT credit - generation of electricity - CENVAT credit of Counterveiling Duty (CVD) on import of Coal - quantum of power wheeled out to sister units - The High Court held that the appellant is entitled to CENVAT credit for the electricity generated, even if wheeled out to sister units, as long as it is used within the company and not sold for consideration.
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