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...
As appeal against the order of Commissioner (Appeals) is pending before the Tribunal, the adjudicating authority dared to pass the impugned order. - This shows that the officers of the department have no respect for the orders passed by the Tribunal and they are following their own law which results in unnecessary litigation before Tribunal - AT
As appeal against the order of Commissioner (Appeals) is pending before the Tribunal, the adjudicating authority dared to pass the impugned order. - This shows that the officers of the department have no respect for the orders passed by the Tribunal and they are following their own law which results in unnecessary litigation before Tribunal - AT
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