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...
Reopening of assessment u/s 147 - filing of objections to the issuance of notice u/s 148A - The day on which the request is made for adjournment either needs approval or rejection, however, once having kept silence and many days to have passed, it cannot suddenly choose to insist on answering within 24 hours as the other-side would also not be wrong in presuming that such a request is already acceded to - HC
Reopening of assessment u/s 147 - filing of objections to the issuance of notice u/s 148A - The day on which the request is made for adjournment either needs approval or rejection, however, once having kept silence and many days to have passed, it cannot suddenly choose to insist on answering within 24 hours as the other-side would also not be wrong in presuming that such a request is already acceded to - HC
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