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 - belief of escapement of income - reopening merely on the information received from the Investigation Wing of the Department, i.e., just on borrowed satisfaction - reassessment cancelled.
Reopening of assessment - belief of escapement of income - reopening merely on the information received from the Investigation Wing of the Department, i.e., just on borrowed satisfaction - reassessment cancelled.
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