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 special audit of the accounts u/s 142(2A) - petitioner has not made any objection regarding procedure followed by the AO or by the Pr. CIT, in the entire process of Special Audit till the completion of Special Audit and only after the fact that the accounts have been verified by the Special Auditor, the present writ petitions have been filed - Petition dismissed.
Validity of special audit of the accounts u/s 142(2A) - petitioner has not made any objection regarding procedure followed by the AO or by the Pr. CIT, in the entire process of Special Audit till the completion of Special Audit and only after the fact that the accounts have been verified by the Special Auditor, the present writ petitions have been filed - Petition dismissed.
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