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...
Assessment u/s 147 - period of limitation u/s 153(2) - contention of the Revenue that the limitation will start again only when the order is communicated to the Department thus cannot be accepted - HC
Assessment u/s 147 - period of limitation u/s 153(2) - contention of the Revenue that the limitation will start again only when the order is communicated to the Department thus cannot be accepted - HC
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