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...
Right to file appeal - Aggrieved person - The counsel for the Respondents could not bring to notice any provision in the Act which would not entitle a person against whom the Order-in-Original is passed, but the tax and penalty has been paid on his behalf by somebody else cannot file an appeal challenging the Order-in-Original. - HC
Right to file appeal - Aggrieved person - The counsel for the Respondents could not bring to notice any provision in the Act which would not entitle a person against whom the Order-in-Original is passed, but the tax and penalty has been paid on his behalf by somebody else cannot file an appeal challenging the Order-in-Original. - HC
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