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...
Survey proceedings - documents impounded under Section 131(3) - there is no provision under the Act to retain the documents of title as security for any tax liability that may arise in the future. In the absence of any such statutory provision, the respondents cannot retain documents of title impounded/seized by them under Section 131(3) of the Act - HC
Survey proceedings - documents impounded under Section 131(3) - there is no provision under the Act to retain the documents of title as security for any tax liability that may arise in the future. In the absence of any such statutory provision, the respondents cannot retain documents of title impounded/seized by them under Section 131(3) of the Act - HC
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