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...
Disclosure of information respecting assessee u/s 138(1)(b) - Since the authority in this case has categorically set out its satisfaction to the effect that furnishing of information is not in 'public interest', assigning reasons for the same, stating that the material sought for appears only to be for settlement of personal disputes between the parties, find no flaw in the order and no cause to interfere in the subjective satisfaction of the Officer. - HC
Disclosure of information respecting assessee u/s 138(1)(b) - Since the authority in this case has categorically set out its satisfaction to the effect that furnishing of information is not in 'public interest', assigning reasons for the same, stating that the material sought for appears only to be for settlement of personal disputes between the parties, find no flaw in the order and no cause to interfere in the subjective satisfaction of the Officer. - HC
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