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 - phrase ‘prejudicial to the interest of the revenue’ - every loss of revenue as a consequence of an order of AO cannot be treated as prejudicial to the interest of revenue - AT
Revision u/s 263 - phrase ‘prejudicial to the interest of the revenue’ - every loss of revenue as a consequence of an order of AO cannot be treated as prejudicial to the interest of revenue - AT
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