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 u/s 147 - notice in the company name being amalgamated -Participation by the amalgamated company in the proceedings would be of no effect as there is no estoppel against law.
Reopening of assessment u/s 147 - notice in the company name being amalgamated -Participation by the amalgamated company in the proceedings would be of no effect as there is no estoppel against law.
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