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...
Appellate order as passed by National Faceless Appeal Centre - NFAC - the centralizedNFAC have chooses to contemptuously ignore the binding precedent of Jurisdictional High Court and have applied the non-jurisdictional High Court decision to deprive the assessee from the benefit of the judicial High Court decision. - A good intentioned and well thought notification issued by the Board for NFAC, is not yielding the desired result on account of incorrect application of law. - AT
Appellate order as passed by National Faceless Appeal Centre - NFAC - the centralizedNFAC have chooses to contemptuously ignore the binding precedent of Jurisdictional High Court and have applied the non-jurisdictional High Court decision to deprive the assessee from the benefit of the judicial High Court decision. - A good intentioned and well thought notification issued by the Board for NFAC, is not yielding the desired result on account of incorrect application of law. - AT
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