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 application rejected - export of consignments - period of limitation - co-relation should have been properly explained by the appellants to the lower authorities which has not been done so, thus issue needs reconsideration - AT
Refund application rejected - export of consignments - period of limitation - co-relation should have been properly explained by the appellants to the lower authorities which has not been done so, thus issue needs reconsideration - AT
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