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...
Power of AC / DC to adjudicate the case u/s 83A where the amount involved is more than ₹ 5,00,000/- - Section 83A is applicable only when penalty is to be adjudged. It is not applicable to amount of tax. - AT
Power of AC / DC to adjudicate the case u/s 83A where the amount involved is more than ₹ 5,00,000/- - Section 83A is applicable only when penalty is to be adjudged. It is not applicable to amount of tax. - AT
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