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 - no notice under section 143(2)- Section 292BB - notice u/s 143(2) is mandatory in reassessment proceedings and it is not a procedural requirement. - in favor of assessee - AT
Reopening of assessment - no notice under section 143(2)- Section 292BB - notice u/s 143(2) is mandatory in reassessment proceedings and it is not a procedural requirement. - in favor of assessee - AT
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