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...
Reassessment u/s 147 - Full and true disclosure – it matters little that the AO did not ask any question or query with respect to one entry or note but had raised queries and questions on other aspects - AT
Reassessment u/s 147 - Full and true disclosure – it matters little that the AO did not ask any question or query with respect to one entry or note but had raised queries and questions on other aspects - AT
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