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 - claiming exemption u/s 11 - assessment came to be reopened by giving notice u/s 148 by the very same officer, who executed the scrutiny assessment and granted exemption - It is a case of change of opinion - Notice quashed - HC
Reopening of assessment - claiming exemption u/s 11 - assessment came to be reopened by giving notice u/s 148 by the very same officer, who executed the scrutiny assessment and granted exemption - It is a case of change of opinion - Notice quashed - HC
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