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...
Invalid jurisdiction - appeal against order of first appellate authority setting aside order passed by the adjudicating authority on the refund claims - Since the authorisation granted to the lower authorities is without jurisdiction, appeal rejected - AT
Invalid jurisdiction - appeal against order of first appellate authority setting aside order passed by the adjudicating authority on the refund claims - Since the authorisation granted to the lower authorities is without jurisdiction, appeal rejected - AT
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