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...
Intimation order under Section 143(1)(a) cannot be treated to be an order of assessment. - it was open for the assessee to submit the revised return at any time before the expiry of one year from the end of the relevant assessment year. - HC
Intimation order under Section 143(1)(a) cannot be treated to be an order of assessment. - it was open for the assessee to submit the revised return at any time before the expiry of one year from the end of the relevant assessment year. - HC
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