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...
Reopening of assessment - reason to believe or reason to suspect - Noting in the loose paper on the basis of which the AO reopened the assessment did not contain any signature of the assessee and it is also not established whether at all any amount was received by the assessee and most important the Department could not bring on record any other corroborative evidences in support of the addition made
Reopening of assessment - reason to believe or reason to suspect - Noting in the loose paper on the basis of which the AO reopened the assessment did not contain any signature of the assessee and it is also not established whether at all any amount was received by the assessee and most important the Department could not bring on record any other corroborative evidences in support of the addition made
Note: It is a system-generated summary and is for quick reference only.
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