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...
Disposal of appeal by CIT(A) - "Central Action Plan” prepared by CBDT - Incentive for quality orders - such guidelines have a propensity to influence the CIT(A) and be tempted to pass an order in a particular manner so as to achieve a greater target of disposal - transgresses in the CIT(A)'s exercise of discretionary quasi-judicial powers - would not stand the test of law - this portion of the impugned Action Plan of CBDT is set aside
Disposal of appeal by CIT(A) - "Central Action Plan” prepared by CBDT - Incentive for quality orders - such guidelines have a propensity to influence the CIT(A) and be tempted to pass an order in a particular manner so as to achieve a greater target of disposal - transgresses in the CIT(A)'s exercise of discretionary quasi-judicial powers - would not stand the test of law - this portion of the impugned Action Plan of CBDT is set aside
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