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...
Revision u/s 263 - Endless enquiry is not possible and it is for the Ld.AO to decide when to end the enquiry. The Ld.CIT cannot transgress the jurisdiction u/s. 263 of the Act by mentioning that no proper enquiry was made. - AT
Revision u/s 263 - Endless enquiry is not possible and it is for the Ld.AO to decide when to end the enquiry. The Ld.CIT cannot transgress the jurisdiction u/s. 263 of the Act by mentioning that no proper enquiry was made. - AT
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