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...
Principle of 'lifting of the corporate veil' - recovery of duty / tax from the director cannot be made merely on the basis of allegation - The test of fraudulent conduct not satisfied, so as to attract the principle of lifting of corporate veil - HC
Principle of 'lifting of the corporate veil' - recovery of duty / tax from the director cannot be made merely on the basis of allegation - The test of fraudulent conduct not satisfied, so as to attract the principle of lifting of corporate veil - HC
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