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...
Commencement of Period of limitation for filing refund claim - the appellant would be entitled for refund within one year from the date of communication of the order because that will be the date on which the assessee can be said to have come to the conclusion that the credit has lapsed and cannot be adjusted any more - AT
Commencement of Period of limitation for filing refund claim - the appellant would be entitled for refund within one year from the date of communication of the order because that will be the date on which the assessee can be said to have come to the conclusion that the credit has lapsed and cannot be adjusted any more - AT
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