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 - there was no negligence on the part of the assessee in furnishing the required details for completing the assessment. Thus reopening of the assessment beyond four years period from the end of the relevant assessment year is not justified - AT
Reopening of assessment - there was no negligence on the part of the assessee in furnishing the required details for completing the assessment. Thus reopening of the assessment beyond four years period from the end of the relevant assessment year is not justified - AT
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