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...
Entitlement to interest for the period starting from the date of deposit till its realization - The impugned order violates principle of judicial discipline and is liable to be set-aside on this ground - the Assistant Commissioner rightly sanctioned the interest by following order dated 03.01.2019 of this Tribunal - AT
Entitlement to interest for the period starting from the date of deposit till its realization - The impugned order violates principle of judicial discipline and is liable to be set-aside on this ground - the Assistant Commissioner rightly sanctioned the interest by following order dated 03.01.2019 of this Tribunal - AT
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