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...
Revision u/s 263 - order passed on a deceased assessee - intimation about Death of assessee - There has been delay at the level of State Government in issuing necessary certificate. Fault cannot be placed on the Revenue or the assessee. - An appellate authority does not have the authority to extend the limitation. - Revision order quashed - AT
Revision u/s 263 - order passed on a deceased assessee - intimation about Death of assessee - There has been delay at the level of State Government in issuing necessary certificate. Fault cannot be placed on the Revenue or the assessee. - An appellate authority does not have the authority to extend the limitation. - Revision order quashed - AT
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