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...
Tribunal was justified in correcting its mistake in exercise of its jurisdiction u/s 254(2) as a patent, manifest and self-evident error which does not require elaborate discussion of evidence or arguments to establish it - HC
Tribunal was justified in correcting its mistake in exercise of its jurisdiction u/s 254(2) as a patent, manifest and self-evident error which does not require elaborate discussion of evidence or arguments to establish it - HC
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