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...
An omission to consider the Ground, which appears in the Memorandum of Appeal filed by the assessee, is a mistake apparent from record within the meaning of section 254(2) of the Act - AT
An omission to consider the Ground, which appears in the Memorandum of Appeal filed by the assessee, is a mistake apparent from record within the meaning of section 254(2) of the Act - AT
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