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...
Provisions relating to reassessment proceedings - In cases where survey under section 133A of the Act is conducted, the AO is deemed to have information for the purposes of sec 148 of the Act but proceedings u/s 148A of the Act need to be conducted prior to issuance of notice u/s 148 of the Act.
Provisions relating to reassessment proceedings - In cases where survey under section 133A of the Act is conducted, the AO is deemed to have information for the purposes of sec 148 of the Act but proceedings u/s 148A of the Act need to be conducted prior to issuance of notice u/s 148 of the Act.
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