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 reopening of assessment - when reference to DVO itself is invalid, the report received as a result of the reference cannot constitute material for forming the belief that an income or wealth tax escaped assessment - AT
Validity of reopening of assessment - when reference to DVO itself is invalid, the report received as a result of the reference cannot constitute material for forming the belief that an income or wealth tax escaped assessment - AT
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