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...
Extended period of limitation - in a previous case involving the same issue, demand was dropped - Therefore, all relevant facts were within the knowledge/ notice of the Department - demand is time barred - SC
Extended period of limitation - in a previous case involving the same issue, demand was dropped - Therefore, all relevant facts were within the knowledge/ notice of the Department - demand is time barred - SC
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