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 the CIT(A) to enhance the assessment u/s 251 - In absence of show cause notice to the assessee stating the defects , allegation and the manner of determining the amount of enhancement and then fixing the date of hearing after affording reasonable time to the assessee to rebut the allegations and then passing a speaking order making enhancement of income is mandatory. - AT
Power of the CIT(A) to enhance the assessment u/s 251 - In absence of show cause notice to the assessee stating the defects , allegation and the manner of determining the amount of enhancement and then fixing the date of hearing after affording reasonable time to the assessee to rebut the allegations and then passing a speaking order making enhancement of income is mandatory. - AT
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