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...
Period of limitation for revision u/s 263 - held that:- limitation would be counted from the reassessment order passed u/s 143(3) r.w.s 147 being the first regular assessment. - AT
Period of limitation for revision u/s 263 - held that:- limitation would be counted from the reassessment order passed u/s 143(3) r.w.s 147 being the first regular assessment. - AT
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