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...
Authorization for search - Status of assessee - existence of AOP/BOI - evidence of existence - after the amendment of the Act by insertion of Section 292 CC with retrospective effect from 1.4.1976, even if the authorization had been issued in the joint names of several persons, assessment in the individual names can be made - HC
Authorization for search - Status of assessee - existence of AOP/BOI - evidence of existence - after the amendment of the Act by insertion of Section 292 CC with retrospective effect from 1.4.1976, even if the authorization had been issued in the joint names of several persons, assessment in the individual names can be made - HC
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