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...
Reopening of assessment u/s 147 - repeat (2nd) Notice under Section 148 - two alleged lacunae or irregularities could not be held to be a sufficient reason for issuing a repeat Notice u/s 148
Reopening of assessment u/s 147 - repeat (2nd) Notice under Section 148 - two alleged lacunae or irregularities could not be held to be a sufficient reason for issuing a repeat Notice u/s 148
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