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...
Rectification of mistake u/s 254(2) - mistake of making an incorrect statement by AR - Order of tribunal was passed relying statement - argument advanced by said counsel are to be construed to have been made on behalf of assessee and shall bind the assessee - not a mistake warranting rectification u/s 254(2)
Rectification of mistake u/s 254(2) - mistake of making an incorrect statement by AR - Order of tribunal was passed relying statement - argument advanced by said counsel are to be construed to have been made on behalf of assessee and shall bind the assessee - not a mistake warranting rectification u/s 254(2)
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