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...
Settlement of a case - assessment proceedings were pending or not - assessment order was passed but not served - Commission has given no finding. We cannot leave the assessee without remedy merely because the Commission chose not to examine such an issue though raised by the assessee.
Settlement of a case - assessment proceedings were pending or not - assessment order was passed but not served - Commission has given no finding. We cannot leave the assessee without remedy merely because the Commission chose not to examine such an issue though raised by the assessee.
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