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...
Coram non-judice - Sufficient safeguard has been provided and looking to the nature of proceedings, cross examination cannot be permitted as a rule rather it can be as an exception. A case of exceptional nature is not made out herein. - AT
Coram non-judice - Sufficient safeguard has been provided and looking to the nature of proceedings, cross examination cannot be permitted as a rule rather it can be as an exception. A case of exceptional nature is not made out herein. - AT
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