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...
Effective Date of Notification - Prescribing tariff value prescribed therein, for the earlier import of R.B.D. Palmolein oil - The High Court noted that in an earlier case the Division Bench had clarified that the notification would be enforceable only from the date it was notified and published in the Official Gazette, i.e., on 06.08.2001. Therefore, any liability accruing from that notification would be applicable only from that date onwards, not from 03.08.2001.
Effective Date of Notification - Prescribing tariff value prescribed therein, for the earlier import of R.B.D. Palmolein oil - The High Court noted that in an earlier case the Division Bench had clarified that the notification would be enforceable only from the date it was notified and published in the Official Gazette, i.e., on 06.08.2001. Therefore, any liability accruing from that notification would be applicable only from that date onwards, not from 03.08.2001.
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