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...
Proper officers - Whether DRI is the proper officer - jurisdiction of DRI to initiate proceedings - In the wake of Section 28(11) ibid, Show Cause Notices issued by DRI do not suffer from any jurisdictional infirmities - AT
Proper officers - Whether DRI is the proper officer - jurisdiction of DRI to initiate proceedings - In the wake of Section 28(11) ibid, Show Cause Notices issued by DRI do not suffer from any jurisdictional infirmities - AT
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