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...
Directions for special audit - Where satisfaction has been arrived at, in bonafide manner after making a genuine and past attempt to understand the accounts and after giving opportunity to the assessee to submit explanation, it cannot be said that unless any of the conditions given in the guidelines are satisfied, special audit cannot be directed - HC
Directions for special audit - Where satisfaction has been arrived at, in bonafide manner after making a genuine and past attempt to understand the accounts and after giving opportunity to the assessee to submit explanation, it cannot be said that unless any of the conditions given in the guidelines are satisfied, special audit cannot be directed - HC
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