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...
Constitutional validity of the third proviso to Section 254(2A) - Vacation of stay order after 365 days - discrimination - where the delay in disposing of the appeal is not attributable to the assessee, Tribunal has the power to grant extension of stay beyond 365 days in deserving cases - HC
Constitutional validity of the third proviso to Section 254(2A) - Vacation of stay order after 365 days - discrimination - where the delay in disposing of the appeal is not attributable to the assessee, Tribunal has the power to grant extension of stay beyond 365 days in deserving cases - HC
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