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...
There was an omission and failure on the part of the assessee to disclose fully and truly material facts for the above assessment years with regard to excess depreciation claimed. - proceeding u/s 147/148. upheld - AT
There was an omission and failure on the part of the assessee to disclose fully and truly material facts for the above assessment years with regard to excess depreciation claimed. - proceeding u/s 147/148. upheld - AT
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