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...
Reassessment proceedings - during the pendency of the proceedings u/s 154 for rectification of error, it was not permissible on the part of the Revenue to initiate the proceedings u/s 147/148 of the Act - The High Court has erred in presuming and observing that the proceedings u/s 154 were invalid because the same were beyond the period of limitation. - SC
Reassessment proceedings - during the pendency of the proceedings u/s 154 for rectification of error, it was not permissible on the part of the Revenue to initiate the proceedings u/s 147/148 of the Act - The High Court has erred in presuming and observing that the proceedings u/s 154 were invalid because the same were beyond the period of limitation. - SC
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