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...
Reopening of assessment - AO had tangible material at his command to form a reasonable belief that income chargeable tax had escaped assessment. In the result, the petition is dismissed.
Reopening of assessment - AO had tangible material at his command to form a reasonable belief that income chargeable tax had escaped assessment. In the result, the petition is dismissed.
Note: It is a system-generated summary and is for quick reference only.
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