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...
Principle of Res-Judicata - While dismissing appeal of Revenue in first ground of litigation, no doubt Supreme court had left question of law open - However, that could not be ground to reopen case of Revenue - SC
Principle of Res-Judicata - While dismissing appeal of Revenue in first ground of litigation, no doubt Supreme court had left question of law open - However, that could not be ground to reopen case of Revenue - SC
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