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...
Validity of Revision of Income Tax Returns (ITR) after the expiry of the due date prescribed under Section 139(5) on account of the pendency of proceedings for amalgamation of the assessee companies with other companies - it is incumbent upon the Department to assess the total income of the successor in respect of the previous assessment year after the date of succession.
Validity of Revision of Income Tax Returns (ITR) after the expiry of the due date prescribed under Section 139(5) on account of the pendency of proceedings for amalgamation of the assessee companies with other companies - it is incumbent upon the Department to assess the total income of the successor in respect of the previous assessment year after the date of succession.
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