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...
Maintainability of appeal - Non-compliance with the pre-deposit of 7.5% or 10%. - any payment made by the appellant during the course of the investigation has to be adjusted against the said percentage of mandatory deposit.
Maintainability of appeal - Non-compliance with the pre-deposit of 7.5% or 10%. - any payment made by the appellant during the course of the investigation has to be adjusted against the said percentage of mandatory deposit.
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