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...
Refund claim - when there is provision of self certification and certification regarding availment of the services, in question, has been given by the assessee, the same has to be accepted unless there are serious doubt about the correctness of the same. - AT
Refund claim - when there is provision of self certification and certification regarding availment of the services, in question, has been given by the assessee, the same has to be accepted unless there are serious doubt about the correctness of the same. - AT
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