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...
Jurisdiction u/s 263 by CIT(A) - AO has failed to take recourse to the provisions of Section 14A - The interference by the C.I.T. was based on facts and not any change of opinion, thus the order of the CIT is restored. - HC
Jurisdiction u/s 263 by CIT(A) - AO has failed to take recourse to the provisions of Section 14A - The interference by the C.I.T. was based on facts and not any change of opinion, thus the order of the CIT is restored. - HC
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