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...
Reopening of Assessment – The provisions contained in Section 151 are indubitably mandatory in nature and since compliance was either not made or could be established by the revenue, benefit will have to be given to the assessee - HC
Reopening of Assessment – The provisions contained in Section 151 are indubitably mandatory in nature and since compliance was either not made or could be established by the revenue, benefit will have to be given to the assessee - HC
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