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...
Service and issuance of notice u/s 143(2) - scope of insertion of Section 292BB - for Section 292BB to apply, the notice must have emanated from the department, it is only the infirmities in the manner of service of notice that the Section seeks to cure - The Section is not intended to cure complete absence of notice itself - issuance of notice u/s 143(2) is mandatory
Service and issuance of notice u/s 143(2) - scope of insertion of Section 292BB - for Section 292BB to apply, the notice must have emanated from the department, it is only the infirmities in the manner of service of notice that the Section seeks to cure - The Section is not intended to cure complete absence of notice itself - issuance of notice u/s 143(2) is mandatory
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