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 - allowability of interest income u/s 80IA - Once the Assessing Officer rejected the claim of deduction under Section 80IA [4] in its entirety, there was thereafter no occasion and any need for him to dissect such claim for rejection on some additional ground. - HC
Reopening of assessment - allowability of interest income u/s 80IA - Once the Assessing Officer rejected the claim of deduction under Section 80IA [4] in its entirety, there was thereafter no occasion and any need for him to dissect such claim for rejection on some additional ground. - HC
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