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 - It was clear that A.O. recorded incorrect and non-existing reasons for reopening of the assessment. Therefore, on the face of it, the reopening of the assessment is void and bad in law. - AT
Reopening of assessment - It was clear that A.O. recorded incorrect and non-existing reasons for reopening of the assessment. Therefore, on the face of it, the reopening of the assessment is void and bad in law. - AT
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