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 264 in favor of assessee - period of limitation of one year is mandatory or directory - the provisions are directory only - CIT directed to decided the application even after lapse of one year - HC
Revision u/s 264 in favor of assessee - period of limitation of one year is mandatory or directory - the provisions are directory only - CIT directed to decided the application even after lapse of one year - HC
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