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...
Rectification of mistake - mistake in charging interest - error apparent on the face of record- there can be variation in charging interest, and such variation can be effected through correction u/s 154 of the Act. - it is always open for the authorities to rectify that mistake.
Rectification of mistake - mistake in charging interest - error apparent on the face of record- there can be variation in charging interest, and such variation can be effected through correction u/s 154 of the Act. - it is always open for the authorities to rectify that mistake.
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