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...
Prima facie case has been made out by the appellant on the ground that the show-cause notice has been issued under a wrong Section and in the absence of issuance of show-cause notice invoking extended period u/s 11A, the demand could not have been sustained- AT
Prima facie case has been made out by the appellant on the ground that the show-cause notice has been issued under a wrong Section and in the absence of issuance of show-cause notice invoking extended period u/s 11A, the demand could not have been sustained- AT
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