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...
Doctrine of Res judicata – There is no question of its being a res judicata so as to bind the A.O. appellate authority or the Tribunal in tax matters so as to decide the matter according to the past transaction only. - HC
Doctrine of Res judicata – There is no question of its being a res judicata so as to bind the A.O. appellate authority or the Tribunal in tax matters so as to decide the matter according to the past transaction only. - HC
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