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 seeks to reopen the assessment on a mere change of opinion inasmuch as, at the time of scrutiny assessment, AO had applied his mind to the issue and even recorded finding in respect thereof in the assessment order framed u/s 143(3) - Notice issued u/s 148 quashed.
Reopening of assessment - AO seeks to reopen the assessment on a mere change of opinion inasmuch as, at the time of scrutiny assessment, AO had applied his mind to the issue and even recorded finding in respect thereof in the assessment order framed u/s 143(3) - Notice issued u/s 148 quashed.
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