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...
Bar of Limitation – Subsequent show cause notice in that case was also issued on the same ground namely that manufacturing company and marketing company were related persons - demand set aside - HC
Bar of Limitation – Subsequent show cause notice in that case was also issued on the same ground namely that manufacturing company and marketing company were related persons - demand set aside - HC
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