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...
Nature of non compete fee received by the assessee - CIT(A) has allowed relief to the assessee - Validity of ITAT order in remanding back the matter to CIT(A) - there was no sufficient material before the Tribunal to remand the case for a fresh consideration at the first instance. - The order of remand set aside.
Nature of non compete fee received by the assessee - CIT(A) has allowed relief to the assessee - Validity of ITAT order in remanding back the matter to CIT(A) - there was no sufficient material before the Tribunal to remand the case for a fresh consideration at the first instance. - The order of remand set aside.
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