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...
Reopening of assessment - expenses under the head "management fees" undisclosed - Assessee had disclosed what was relevant and necessary for the purpose of making assessment - this is a clear case of change of opinion - HC
Reopening of assessment - expenses under the head "management fees" undisclosed - Assessee had disclosed what was relevant and necessary for the purpose of making assessment - this is a clear case of change of opinion - HC
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