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...
Re-opening of assessment u/s 147 - non disposal of objection neither by a separate order nor in the final assessment order which is very essential to decide the same before completing the assessment and against the spirit of the direction of the Hon’ble Supreme Court - CIT(A) has also not taken into consideration the objection filed by the assessee - remanded to AO
Re-opening of assessment u/s 147 - non disposal of objection neither by a separate order nor in the final assessment order which is very essential to decide the same before completing the assessment and against the spirit of the direction of the Hon’ble Supreme Court - CIT(A) has also not taken into consideration the objection filed by the assessee - remanded to AO
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