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...
Since in the instant case, the department has not been able to demonstrate that notice u/s. 143(2) was served within the statutory time limit, the assessment made on the basis of such invalid notice could not be treated to be valid assessment - AT
Since in the instant case, the department has not been able to demonstrate that notice u/s. 143(2) was served within the statutory time limit, the assessment made on the basis of such invalid notice could not be treated to be valid assessment - AT
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