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...
Extended period of limitation - The appellant has disclosed the entire information in their Annual Accounts and at the time of filing of ST-3 returns. The Commissioner reasoning that as the appellant have not sought classification from the department, extended period would be invokable, cannot be appreciated - demand barred by limitation.
Extended period of limitation - The appellant has disclosed the entire information in their Annual Accounts and at the time of filing of ST-3 returns. The Commissioner reasoning that as the appellant have not sought classification from the department, extended period would be invokable, cannot be appreciated - demand barred by limitation.
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