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...
Rejection of appeals - The order passed u/s. 263 cannot come into the way of ld. CIT(A) to dispose the appeal filed by assessee against impugned assessment orders as these proceedings are independent proceedings - AT
Rejection of appeals - The order passed u/s. 263 cannot come into the way of ld. CIT(A) to dispose the appeal filed by assessee against impugned assessment orders as these proceedings are independent proceedings - AT
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