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 the assessment orders u/s 153A, r.w.s. 143(3) - period of limitation - if no seizure is made on that date and nothing is done except lifting the prohibitory orders then the last punchnama drawn on that date would not be relevant to compute the limitation period for framing the assessment. - AT
Validity of the assessment orders u/s 153A, r.w.s. 143(3) - period of limitation - if no seizure is made on that date and nothing is done except lifting the prohibitory orders then the last punchnama drawn on that date would not be relevant to compute the limitation period for framing the assessment. - AT
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