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...
Treatment as a resident in India - Passport being unjustifiably impounded - it was impossible for the assessee to leave India - He virtually became an unwilling resident on Indian soil without his consent and against his will - such period must be excluded - Cannot be treated as Resident - HC
Treatment as a resident in India - Passport being unjustifiably impounded - it was impossible for the assessee to leave India - He virtually became an unwilling resident on Indian soil without his consent and against his will - such period must be excluded - Cannot be treated as Resident - HC
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