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...
Revised return u/s 139(5) - Exemption u/s 10(35)/ 10(33) - AO must not take advantage of ignorance of the assessee as to his rights - The matter was remanded to the AO to consider the case on merits and decide accordingly - HC
Revised return u/s 139(5) - Exemption u/s 10(35)/ 10(33) - AO must not take advantage of ignorance of the assessee as to his rights - The matter was remanded to the AO to consider the case on merits and decide accordingly - HC
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