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 - order under section 263 of the Act was required to be passed within two years from the end of the financial year in which the order sought to be revised was passed - HC
Revision u/s 263 - order under section 263 of the Act was required to be passed within two years from the end of the financial year in which the order sought to be revised was passed - HC
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