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...
Extended period of limitation - the genesis for issuing show-cause notice for extended period of limitation is from the very material on record before the authority - The appellant since unable to attack a crucial finding of fact recorded by the Tribunal, necessarily must fail in the challenge against the order impugned in the appeal. - HC
Extended period of limitation - the genesis for issuing show-cause notice for extended period of limitation is from the very material on record before the authority - The appellant since unable to attack a crucial finding of fact recorded by the Tribunal, necessarily must fail in the challenge against the order impugned in the appeal. - HC
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