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...
Initiation of proceedings u/s 158BD - unless the basic finding is held to be valid, the consequential order is bad in law - since there was no notice served under section 158 BC the assessee could not have been assessed under section 158BD - HC
Initiation of proceedings u/s 158BD - unless the basic finding is held to be valid, the consequential order is bad in law - since there was no notice served under section 158 BC the assessee could not have been assessed under section 158BD - HC
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