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...
There cannot be one order of assessment by AO for the same period for which the Commission would also pass the order of settlement. Accepting the contention that even if the order of assessment has been passed by the AO, his case may still be deemed to be pending since such order was not dispatched or served, would lead to a conflicting situation - HC
There cannot be one order of assessment by AO for the same period for which the Commission would also pass the order of settlement. Accepting the contention that even if the order of assessment has been passed by the AO, his case may still be deemed to be pending since such order was not dispatched or served, would lead to a conflicting situation - HC
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