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...
Power of the AO to rectify mistake of his super senior officer u/s 154 - tax calculation mistake - hierarchy of the Departmental structure - AO is not validly entitled and empowered to rectify mistake of his super senior officer - Sole grievance of assessee is allowed. - AT
Power of the AO to rectify mistake of his super senior officer u/s 154 - tax calculation mistake - hierarchy of the Departmental structure - AO is not validly entitled and empowered to rectify mistake of his super senior officer - Sole grievance of assessee is allowed. - AT
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