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...
Assessment u/s 147, when the assessment u/s 142(1)(a); 143(3); or 144 has not been done – Without passing the assessment order, there is no occasion to pass the re-assessment order under Section 147 of the Act - HC
Assessment u/s 147, when the assessment u/s 142(1)(a); 143(3); or 144 has not been done – Without passing the assessment order, there is no occasion to pass the re-assessment order under Section 147 of the Act - HC
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