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...
Revision u/s 263 - disallowance u/s 14A - where the Assessing Officer had recorded the satisfaction as required under section 14A of the Act, made enquiries and accepted the calculations of the assessee, such an order passed by the Assessing Officer cannot be said to be erroneous - AT
Revision u/s 263 - disallowance u/s 14A - where the Assessing Officer had recorded the satisfaction as required under section 14A of the Act, made enquiries and accepted the calculations of the assessee, such an order passed by the Assessing Officer cannot be said to be erroneous - AT
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