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...
Extended Period of Limitation – when the earlier show cause notices had been issued for the later period on the same set of facts - SCN for earlier period not valid - HC
Extended Period of Limitation – when the earlier show cause notices had been issued for the later period on the same set of facts - SCN for earlier period not valid - HC
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