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...
Power of revision under section 263 – Amendment to Explanation to Section 115 JB - subsequent amendment in 2005 even though retrospective will not attract the provision of Section 263 - HC
Power of revision under section 263 – Amendment to Explanation to Section 115 JB - subsequent amendment in 2005 even though retrospective will not attract the provision of Section 263 - HC
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