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...
Reopening of Assessment u/s 147 - From the facts on record, it was not possible for the AO to ascertain that received interest was higher than the normal rate of interest - against assessee - HC
Reopening of Assessment u/s 147 - From the facts on record, it was not possible for the AO to ascertain that received interest was higher than the normal rate of interest - against assessee - HC
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