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...
Non passing of speaking order - if the adjudicating authority has not followed direction issued by Commissioner (Appeals), the remedy lies in taking up the matter with the jurisdictional Executive Commissioner - appeal dismissed - AT
Non passing of speaking order - if the adjudicating authority has not followed direction issued by Commissioner (Appeals), the remedy lies in taking up the matter with the jurisdictional Executive Commissioner - appeal dismissed - AT
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