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...
Validity of reopening of assessment – the foundation of the reopening itself being erroneous insofar as the reasons recorded are erroneous and are not supported by any evidence but are contrary to the evidence as are available on record - AT
Validity of reopening of assessment – the foundation of the reopening itself being erroneous insofar as the reasons recorded are erroneous and are not supported by any evidence but are contrary to the evidence as are available on record - AT
Note: It is a system-generated summary and is for quick reference only.
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