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...
Reassessment u/s 147 - in these facts that the assessee could not have placed on record the required documents within any notice at all before section 133(6)/131 process - Mere on non production of the notice(s) in question; in our considered view, is not sufficient to conclude that the AO had not issued sec. 143(2) and sec. 142(1) - AT
Reassessment u/s 147 - in these facts that the assessee could not have placed on record the required documents within any notice at all before section 133(6)/131 process - Mere on non production of the notice(s) in question; in our considered view, is not sufficient to conclude that the AO had not issued sec. 143(2) and sec. 142(1) - AT
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