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...
Reference to Valuation officer (DVO) - Section 142A would not be applicable to the assessment made on or before 30.9.2004 and which has become final and conclusive on or before that date - HC
Reference to Valuation officer (DVO) - Section 142A would not be applicable to the assessment made on or before 30.9.2004 and which has become final and conclusive on or before that date - HC
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