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...
Refund claim - Reassessment was required to be done by the proper officer and is admittedly not in the hands of assessee. - Revenue cannot be allowed to have the benefit of its own lapses. - AT
Refund claim - Reassessment was required to be done by the proper officer and is admittedly not in the hands of assessee. - Revenue cannot be allowed to have the benefit of its own lapses. - AT
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