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 assessment - CIT(A) had a mistaken belief that issuance of notice u/s 143(2) is an empty formality inspite of the legal position on this statutory mandate - it throws a very public glare on the “serious malaise” which the tax administration can be said to be infected with - AT
Validity of assessment - CIT(A) had a mistaken belief that issuance of notice u/s 143(2) is an empty formality inspite of the legal position on this statutory mandate - it throws a very public glare on the “serious malaise” which the tax administration can be said to be infected with - AT
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