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...
Reopening of assessment - the "reasons recorded" by the Assessing Officer for reopening the case under section 147 is bad in law as there is no reason to believe or any relevant material on the basis of which the assessee's case can be reopened. - AT
Reopening of assessment - the "reasons recorded" by the Assessing Officer for reopening the case under section 147 is bad in law as there is no reason to believe or any relevant material on the basis of which the assessee's case can be reopened. - AT
Note: It is a system-generated summary and is for quick reference only.
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