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...
The action of reopening of assessment can be resorted to by the AO only if he has tangible material at his command to form a reasonable belief that income chargeable to tax had escaped assessment. Such belief of the AO cannot be substituted by that of the opinion of the audit party - HC
The action of reopening of assessment can be resorted to by the AO only if he has tangible material at his command to form a reasonable belief that income chargeable to tax had escaped assessment. Such belief of the AO cannot be substituted by that of the opinion of the audit party - HC
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