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 - when a specific direction has been given by the Additional Commissioner u/s 144A of the Act for passing an order u/s 143(3) of the Act on a specific issue, assessment cannot be reopened on the same issue - AO has no power of review - AT
Reopening of assessment - when a specific direction has been given by the Additional Commissioner u/s 144A of the Act for passing an order u/s 143(3) of the Act on a specific issue, assessment cannot be reopened on the same issue - AO has no power of review - AT
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