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...
Merger of order passed u/s 254(2) with main order of Tribunal - set off of brought forward losses and unabsorbed depreciation - the order passed in the miscellaneous petition stood merged with the earlier order and the composite order being questioned before the Court and the challenge at the instance of the revenue having been rejected then appeal against main order is not maintainable
Merger of order passed u/s 254(2) with main order of Tribunal - set off of brought forward losses and unabsorbed depreciation - the order passed in the miscellaneous petition stood merged with the earlier order and the composite order being questioned before the Court and the challenge at the instance of the revenue having been rejected then appeal against main order is not maintainable
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