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...
Revision u/s 263 - source of purchase declared was examined by AO but unrealistically lower costs of purchases not examined - no relevant meaningful inquiry was conducted in respect to correctness of the cost of purchase of land - lack of inquiry - Revision justified
Revision u/s 263 - source of purchase declared was examined by AO but unrealistically lower costs of purchases not examined - no relevant meaningful inquiry was conducted in respect to correctness of the cost of purchase of land - lack of inquiry - Revision justified
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