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 - condition precedent necessary under Section 151(1) not complied - recording of satisfaction - issue of notice after 4 years - the impugned notice under Section 148 stands setaside /quashed - HC
Reopening of assessment - condition precedent necessary under Section 151(1) not complied - recording of satisfaction - issue of notice after 4 years - the impugned notice under Section 148 stands setaside /quashed - HC
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