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...
Validity of order passed after inordinate delay of 2 years in passing the order - it would be in the interest of natural justice to remand the matter back to the adjudicating authority for denovo adjudication. - AT
Validity of order passed after inordinate delay of 2 years in passing the order - it would be in the interest of natural justice to remand the matter back to the adjudicating authority for denovo adjudication. - AT
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