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...
Reference to the DVO - Proceedings u/s 153-C has been held without jurisdiction - whether reference to DVO in 153-C proceeding is valid - Once the very basis for referring the matter to the Departmental Valuation Officer has vanished, the entire proceedings cannot be held to be justified.
Reference to the DVO - Proceedings u/s 153-C has been held without jurisdiction - whether reference to DVO in 153-C proceeding is valid - Once the very basis for referring the matter to the Departmental Valuation Officer has vanished, the entire proceedings cannot be held to be justified.
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