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...
Scrutiny assessment - issuance of notice u/s 143(2) - Non compliance of assessee v/s Non compliance of AO - Can assessee take advantage of his own non compliance - Revenue should be given full opportunity by the CIT(A) to canvass all the grounds.
Scrutiny assessment - issuance of notice u/s 143(2) - Non compliance of assessee v/s Non compliance of AO - Can assessee take advantage of his own non compliance - Revenue should be given full opportunity by the CIT(A) to canvass all the grounds.
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