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...
Reassessment notice u/s 148 - after four years of the assessment u/s 143(3) - allowabllity of carry forward the losses when return filed u/s 139(4) - petitioner is not guilty of not disclosing fully and truly all material facts - notice quashed
Reassessment notice u/s 148 - after four years of the assessment u/s 143(3) - allowabllity of carry forward the losses when return filed u/s 139(4) - petitioner is not guilty of not disclosing fully and truly all material facts - notice quashed
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