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...
Revised return u/s 139(5) rejected - Revision in the sales figure - in a case assessee files the revised return then it is to be taken into consideration for the purpose of making an assessment and the original return cannot be adverted.
Revised return u/s 139(5) rejected - Revision in the sales figure - in a case assessee files the revised return then it is to be taken into consideration for the purpose of making an assessment and the original return cannot be adverted.
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