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...
Order u/s 201(1)/201(1A) - sufficient opportunity - the date of orders passed by the AO reveal that from the date of issuance of SCN to the date of passing of orders u/s. 201(1) and 201(1A) is less than one month - the information sought by the AO from the assessee is about six years old. It takes time to retrieve the old information - sufficient opportunity was not afforded - matter remanded
Order u/s 201(1)/201(1A) - sufficient opportunity - the date of orders passed by the AO reveal that from the date of issuance of SCN to the date of passing of orders u/s. 201(1) and 201(1A) is less than one month - the information sought by the AO from the assessee is about six years old. It takes time to retrieve the old information - sufficient opportunity was not afforded - matter remanded
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