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...
Assessee in default u/s. 206C(6A) - non-collection of tax at source on sale of heavy scrap - SCN in the instant case has been issued after five years - Thus, in the absence of statutory time limit prescribed for passing order with reference to collection of taxes, principle of reasonable time limit to be followed - AT
Assessee in default u/s. 206C(6A) - non-collection of tax at source on sale of heavy scrap - SCN in the instant case has been issued after five years - Thus, in the absence of statutory time limit prescribed for passing order with reference to collection of taxes, principle of reasonable time limit to be followed - AT
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