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...
Valuation - the case of enhancement of value are merely based on NIDB data, when such documents relating NIDB data were not even supplied to the appellants, thus not following principles of Natural Justice, value cannot be enhanced - AT
Valuation - the case of enhancement of value are merely based on NIDB data, when such documents relating NIDB data were not even supplied to the appellants, thus not following principles of Natural Justice, value cannot be enhanced - AT
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