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...
Additional evidence - rule 46A - Appellate authority should not refuse to make enquiry in the case where facts and circumstances so demand - CIT(A) directed to consider the additional evidence - AT
Additional evidence - rule 46A - Appellate authority should not refuse to make enquiry in the case where facts and circumstances so demand - CIT(A) directed to consider the additional evidence - AT
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