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...
There was no cross appeal filed by the Revenue before the Commissioner (Appeals). In such a scenario, we agree with the ld. Advocate that the impugned order passed by the Commissioner (Appeals) had travelled beyond the scope of the appeal before him and is required to be set aside on the said ground itself. - AT
There was no cross appeal filed by the Revenue before the Commissioner (Appeals). In such a scenario, we agree with the ld. Advocate that the impugned order passed by the Commissioner (Appeals) had travelled beyond the scope of the appeal before him and is required to be set aside on the said ground itself. - AT
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