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 – Even if the materials/evidence was not enclosed with the return, full and true details/material was disclosed during the course of the original proceedings - re-assessment order quashed - HC
Reopening of assessment – Even if the materials/evidence was not enclosed with the return, full and true details/material was disclosed during the course of the original proceedings - re-assessment order quashed - HC
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