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...
Power of CIT(A) u/s 151 - enhancement of income - CIT(A) has erred in exceeding his jurisdiction by enhancing income from a fresh source that was neither part of return of income nor touched upon by the Assessing Officer in proceeding u/s. 143(3).
Power of CIT(A) u/s 151 - enhancement of income - CIT(A) has erred in exceeding his jurisdiction by enhancing income from a fresh source that was neither part of return of income nor touched upon by the Assessing Officer in proceeding u/s. 143(3).
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