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...
Assessee had failed to pay tax due on the income returned at the time of filing the return or even before filing of appeal or even at the time when appeal was heard by the ld CIT(A) - CIT(A) rightly refused to admit Appeal since requirements of section 249(4)(a) not fulfilled - AT
Assessee had failed to pay tax due on the income returned at the time of filing the return or even before filing of appeal or even at the time when appeal was heard by the ld CIT(A) - CIT(A) rightly refused to admit Appeal since requirements of section 249(4)(a) not fulfilled - AT
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