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...
Validity of reopening of assessment u/s 147 - Addition u/s 56(2)(v) - gifts received by the assessee from the HUF interpreted as the gift from the relatives - reopening the assessment on the same issue which was already considered by the AO and taken a view amounts to difference of opinion and on difference of opinion, reopening of assessment is not permissible
Validity of reopening of assessment u/s 147 - Addition u/s 56(2)(v) - gifts received by the assessee from the HUF interpreted as the gift from the relatives - reopening the assessment on the same issue which was already considered by the AO and taken a view amounts to difference of opinion and on difference of opinion, reopening of assessment is not permissible
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