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...
Revised return - original return of income was filed within time - Revised return is a loss return which should have been filed within the time specified u/s 139(3) of the Act - loss return filed beyond the time limit prescribed u/s 139(3) of the Act was null and void - AT
Revised return - original return of income was filed within time - Revised return is a loss return which should have been filed within the time specified u/s 139(3) of the Act - loss return filed beyond the time limit prescribed u/s 139(3) of the Act was null and void - AT
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