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...
When no scrutiny assessment could have been completed in this case, AO is perfectly justified to invoke reassessment proceeding by issuance of notice under section 148 of the Act. - AT
When no scrutiny assessment could have been completed in this case, AO is perfectly justified to invoke reassessment proceeding by issuance of notice under section 148 of the Act. - AT
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