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...
The Revenue’s emphasis for treating the assessee’s section 153A return as belated is without any merit since the same was very much treated as a valid one as per the assessment order and more so, in view of the fact that the Assessing Officer made other disallowance/additions on merits as well
The Revenue’s emphasis for treating the assessee’s section 153A return as belated is without any merit since the same was very much treated as a valid one as per the assessment order and more so, in view of the fact that the Assessing Officer made other disallowance/additions on merits as well
Note: It is a system-generated summary and is for quick reference only.
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