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...
TPA - The use of word ‘shall’ in sub-section (13) shows that it is mandatory on the part of Assessing Officer to pass the final assessment order by only implementing the directions of the DRP- AT
TPA - The use of word ‘shall’ in sub-section (13) shows that it is mandatory on the part of Assessing Officer to pass the final assessment order by only implementing the directions of the DRP- AT
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