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 u/s 147 - In the instant case, the A. O. has disposed of the objections of the petitioner by passing a speaking order considering all legal and factual aspects, which are just and proper, and do not call for any interference by this Court, exercising the jurisdiction under Article 226 of the Constitution of India. - HC
Reopening of assessment u/s 147 - In the instant case, the A. O. has disposed of the objections of the petitioner by passing a speaking order considering all legal and factual aspects, which are just and proper, and do not call for any interference by this Court, exercising the jurisdiction under Article 226 of the Constitution of India. - HC
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