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...
Issue was not raised before Commissioner (Appeal) or CESTAT - the appeal shall be heard only on the question so formulated, this court is of the view that the applicant is not entitled to the relief prayed for in the present application. - HC
Issue was not raised before Commissioner (Appeal) or CESTAT - the appeal shall be heard only on the question so formulated, this court is of the view that the applicant is not entitled to the relief prayed for in the present application. - HC
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