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...
Power u/s 254(2) cannot be exercised unless and until grave error on facts/law from the record is pointed out which is apparent on its face causing apparent injustice to the assessee. - AT
Power u/s 254(2) cannot be exercised unless and until grave error on facts/law from the record is pointed out which is apparent on its face causing apparent injustice to the assessee. - AT
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