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...
Levy of interest - assessee has neither offered seized cash during his statement u/s 132(4) nor he intimated to the Department by letter that his seized cash should be adjusted towards his advance tax/tax liability - Demand confirmed.
Levy of interest - assessee has neither offered seized cash during his statement u/s 132(4) nor he intimated to the Department by letter that his seized cash should be adjusted towards his advance tax/tax liability - Demand confirmed.
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