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...
Validity of assessment u/s 153A - approval u/s 153D - approving authority has directed the DCIT to ensure the seized materials and the findings of the appraisal report to be incorporated in the final assessment order which clearly goes to proves that the approval given by the JCIT is not a final approval as required u/s 153D on final draft assessment order - order by the DCIT do not stand in the eyes of law
Validity of assessment u/s 153A - approval u/s 153D - approving authority has directed the DCIT to ensure the seized materials and the findings of the appraisal report to be incorporated in the final assessment order which clearly goes to proves that the approval given by the JCIT is not a final approval as required u/s 153D on final draft assessment order - order by the DCIT do not stand in the eyes of law
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