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...
Suo moto adjustment of sanctioned refund against the demand - the demand confirmed been already sub-judiced before the competent authority - The question of suo moto adjusting the sanctioned refund qua the said demand therefore does not arise.
Suo moto adjustment of sanctioned refund against the demand - the demand confirmed been already sub-judiced before the competent authority - The question of suo moto adjusting the sanctioned refund qua the said demand therefore does not arise.
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