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...
Invalid approval obtained u/s 153D for assessment u/s 153A - Approval from Addl. CIT of the Range - So, when mandatory approval u/s 153D is not there, entire assessment made by the AO u/s 153A/143(3) is not sustainable as it is no approval in the eyes of law
Invalid approval obtained u/s 153D for assessment u/s 153A - Approval from Addl. CIT of the Range - So, when mandatory approval u/s 153D is not there, entire assessment made by the AO u/s 153A/143(3) is not sustainable as it is no approval in the eyes of law
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