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...
Rectification u/s 154 - AO is not justified in initiating further proceedings for rectification to impose his own view under the guise of rectification under Section 154 - HC
Rectification u/s 154 - AO is not justified in initiating further proceedings for rectification to impose his own view under the guise of rectification under Section 154 - HC
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