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...
Territorial jurisdiction of AO Kolkata - TDS liability - power to make the assessment - ITAT decided in favor of assessee, on ground of passage of time, without touching the basic issue of TDS liability of the assessee - Matter restored before the tribunal with direction.
Territorial jurisdiction of AO Kolkata - TDS liability - power to make the assessment - ITAT decided in favor of assessee, on ground of passage of time, without touching the basic issue of TDS liability of the assessee - Matter restored before the tribunal with direction.
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