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...
Validity of Circular - The Board could not have issued the circular for rendering a decision of the Tribunal as irrelevant and nugatory - The remedy actually was to challenge and question the ratio in appropriate proceedings - HC
Validity of Circular - The Board could not have issued the circular for rendering a decision of the Tribunal as irrelevant and nugatory - The remedy actually was to challenge and question the ratio in appropriate proceedings - HC
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