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...
Revised return - rectified return was in fact a new return - u/s 139 (5), it is not open either to rectify or to revise return after there was a delay in filing a said return in time - HC
Revised return - rectified return was in fact a new return - u/s 139 (5), it is not open either to rectify or to revise return after there was a delay in filing a said return in time - HC
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