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 assessment order - period of limitation - CIT(A) annulled the assessment order - Settlement Commission rejected the application on the grounds that the admitted tax and interest on the income disclosed had not been paid - Since AO has passed the order within 60 days from from the order of the ITSC, the order of CIT(A) cannot be sustained.
Validity of assessment order - period of limitation - CIT(A) annulled the assessment order - Settlement Commission rejected the application on the grounds that the admitted tax and interest on the income disclosed had not been paid - Since AO has passed the order within 60 days from from the order of the ITSC, the order of CIT(A) cannot be sustained.
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