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...
The provisions of statute, as contained in sub-section (8) of section 144C, clearly prohibits the DRP to delegate its power to the AO i.e., to set aside the variation or issue any direction to carry out any further enquiry by the AO- AT
The provisions of statute, as contained in sub-section (8) of section 144C, clearly prohibits the DRP to delegate its power to the AO i.e., to set aside the variation or issue any direction to carry out any further enquiry by the AO- AT
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