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 - AO must have some tangible material having live link with the escapement of the income on the basis of which he can form a bonafide belief of escapement of income chargeable to tax - HC
Reopening of assessment - AO must have some tangible material having live link with the escapement of the income on the basis of which he can form a bonafide belief of escapement of income chargeable to tax - HC
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