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...
Reopening of assessment - Capital gain - transfer u/s 2(47) - the assessee were inconsistent in their stand at different point of time - the decisions relied on learned counsel for the appealant can be of no assistance to the case of the assessee
Reopening of assessment - Capital gain - transfer u/s 2(47) - the assessee were inconsistent in their stand at different point of time - the decisions relied on learned counsel for the appealant can be of no assistance to the case of the assessee
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