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...
Reopening of assessment u/s 147 - reopening on the basis of retrospective amendment relating to diminution in the value of any asset is required to be added to the book profit for the purposes of Section 115-JB - the retrospective amendment to any provision cannot be a ground for making re-assessment
Reopening of assessment u/s 147 - reopening on the basis of retrospective amendment relating to diminution in the value of any asset is required to be added to the book profit for the purposes of Section 115-JB - the retrospective amendment to any provision cannot be a ground for making re-assessment
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