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...
Refund of pre-deposit - Section 35F read with Section 35FF does not provide for any refund application to be made by the assessee after being successful in appeal - the limitation prescribed under Section 11B is not applicable for refund claim under Section 35FF. - AT
Refund of pre-deposit - Section 35F read with Section 35FF does not provide for any refund application to be made by the assessee after being successful in appeal - the limitation prescribed under Section 11B is not applicable for refund claim under Section 35FF. - AT
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