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...
Judicial discipline - Power of CIT(A) u/s 251 vis a vis CIT u/s 263 - If any part of the income has escaped assessment, it is the jurisdiction of the administrative CIT u/s 263 and not of CIT(A). - AT
Judicial discipline - Power of CIT(A) u/s 251 vis a vis CIT u/s 263 - If any part of the income has escaped assessment, it is the jurisdiction of the administrative CIT u/s 263 and not of CIT(A). - AT
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