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...
Reopening of assessment - Assumption of jurisdiction by the A.O for disturbing a concluded assessment of an assessee based on a “change of opinion” is not permitted under law - Re-Assessment order quashed - AT
Reopening of assessment - Assumption of jurisdiction by the A.O for disturbing a concluded assessment of an assessee based on a “change of opinion” is not permitted under law - Re-Assessment order quashed - AT
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