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...
If assessee was not liable to pay the tax in question, the department had no business to retain it even if it was wrongly paid - In case it is not a case of Revision u/s 264, authorities could have invoked section 119.
If assessee was not liable to pay the tax in question, the department had no business to retain it even if it was wrongly paid - In case it is not a case of Revision u/s 264, authorities could have invoked section 119.
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