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...
Notice U/s 148 & 142(1) - Non issuance of notice u/s 143(2) - So long as the ingredients of section 147 are fulfilled, the Assessing Officer is free to initiate proceeding - HC
Notice U/s 148 & 142(1) - Non issuance of notice u/s 143(2) - So long as the ingredients of section 147 are fulfilled, the Assessing Officer is free to initiate proceeding - HC
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