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...
Protective assessment converted as substantive assessment – when there are two assessments, one on protective basis and other on substantial basis, it is always advisable to adjudicate both the issues simultaneously - AT
Protective assessment converted as substantive assessment – when there are two assessments, one on protective basis and other on substantial basis, it is always advisable to adjudicate both the issues simultaneously - AT
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