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...
Enhancement of assessment u/s 251 - additions were made by the CIT(A) in first round - matter was remanded back by ITAT to CIT(A) - assessee sought the adjournment - CIT(A) not satisfied with the reasons mentioned by the assessee and the Ld. CIT(A) has determined the income of the assessee on already determined income - Order cancelled - AT
Enhancement of assessment u/s 251 - additions were made by the CIT(A) in first round - matter was remanded back by ITAT to CIT(A) - assessee sought the adjournment - CIT(A) not satisfied with the reasons mentioned by the assessee and the Ld. CIT(A) has determined the income of the assessee on already determined income - Order cancelled - AT
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