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...
Extension of time limit for issuance of SCN - amended provision of Section 110 (2) - SCN was not issued within the period 6 months - there is no legal authority with the department for dispensing with the issuance of SCN to the appellant - the impugned order passed without issuance of any SCN will not sustain
Extension of time limit for issuance of SCN - amended provision of Section 110 (2) - SCN was not issued within the period 6 months - there is no legal authority with the department for dispensing with the issuance of SCN to the appellant - the impugned order passed without issuance of any SCN will not sustain
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