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...
Order u/s 201(1)/201(1A) of the Act – four years was a reasonable period for passing an order u/s 201(1)/201(1A), particularly when no limitation was prescribed - AT
Order u/s 201(1)/201(1A) of the Act – four years was a reasonable period for passing an order u/s 201(1)/201(1A), particularly when no limitation was prescribed - AT
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