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...
Re-opening of assessment u/s 147 of the Act on the basis of D.V.O.'s report - the opinion of the DVO per se is not an information for the purposes of reopening assessment - HC
Re-opening of assessment u/s 147 of the Act on the basis of D.V.O.'s report - the opinion of the DVO per se is not an information for the purposes of reopening assessment - HC
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