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...
Reopening of assessment - revenue had an efficacious remedy open to it in the form of a rectification u/s 154 for correcting a computational error and consequently recourse to the provisions of section 147 was not warranted - AT
Reopening of assessment - revenue had an efficacious remedy open to it in the form of a rectification u/s 154 for correcting a computational error and consequently recourse to the provisions of section 147 was not warranted - AT
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