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...
Issuance of show cause notice – Commissioner could not have issued show cause notice as prior order of Commissioner had merged into order passed by revisionary authority and principles of res judicata applied - department is allowed to pursue other legal remedies - SC
Issuance of show cause notice – Commissioner could not have issued show cause notice as prior order of Commissioner had merged into order passed by revisionary authority and principles of res judicata applied - department is allowed to pursue other legal remedies - SC
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