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...
Validity of revised return - delay in filing ROI - It is a settled position of law through various judicial pronouncements and section 10 of General Clauses Act and also by Board’s Circular that if the last day of filing of return happens to be a holiday, the return can be filed on next working day.
Validity of revised return - delay in filing ROI - It is a settled position of law through various judicial pronouncements and section 10 of General Clauses Act and also by Board’s Circular that if the last day of filing of return happens to be a holiday, the return can be filed on next working day.
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