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...
Reassessment u/s 147 - reopening based on dictation/instance of the investigation wing - the authority, indicating the information was of the equal rank and not a higher authority - the AO is merely advised to take any remedial actions in accordance with the law - no instance of or at the dictate of higher authorities - reopening upheld
Reassessment u/s 147 - reopening based on dictation/instance of the investigation wing - the authority, indicating the information was of the equal rank and not a higher authority - the AO is merely advised to take any remedial actions in accordance with the law - no instance of or at the dictate of higher authorities - reopening upheld
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