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...
Revision u/s 263 - assessee claimed deduction as loan written back under OTS scheme, considering it as “ capital receipt” not liable to tax - the order directing the A.O. to carry through proper enquiry cannot be said to be liable to be set aside.
Revision u/s 263 - assessee claimed deduction as loan written back under OTS scheme, considering it as “ capital receipt” not liable to tax - the order directing the A.O. to carry through proper enquiry cannot be said to be liable to be set aside.
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