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...
Review petition - Reassessment u/s 147 - Scope of the proviso to the Section 14A - The proviso is not procedural but guarantees vested rights of parties against reopening concluded assessments. - HC
Review petition - Reassessment u/s 147 - Scope of the proviso to the Section 14A - The proviso is not procedural but guarantees vested rights of parties against reopening concluded assessments. - HC
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