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...
Introduction of the authority of Joint Commissioner (Appeals) - In order to reduce burden or bottleneck of small cases with small amount of disputes and demand from commissioner of Appeals as it is first authority of appeal, it is proposed to be created at Joint Commissioner/ Additional Commissioner level. Such authority has all powers, responsibilities and accountability similar to that of Commissioner (Appeals) with respect to the procedure for disposal of appeals.
Introduction of the authority of Joint Commissioner (Appeals) - In order to reduce burden or bottleneck of small cases with small amount of disputes and demand from commissioner of Appeals as it is first authority of appeal, it is proposed to be created at Joint Commissioner/ Additional Commissioner level. Such authority has all powers, responsibilities and accountability similar to that of Commissioner (Appeals) with respect to the procedure for disposal of appeals.
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