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 - AO has blindly gone by the objections raised by the Revenue’s Audit party without his own independent application of mind or the actual verification of the assessment records. - reopening of assessment u/s.147 in terms of aforesaid “reasons recorded” is unjustified in law - AT
Reopening of assessment - AO has blindly gone by the objections raised by the Revenue’s Audit party without his own independent application of mind or the actual verification of the assessment records. - reopening of assessment u/s.147 in terms of aforesaid “reasons recorded” is unjustified in law - AT
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