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...
Procedure of Conducting the search and seizure of the digital data from the premises of the petitioner - seizure of the .txt files from an undisclosed location - Digital Evidence Investigation Manual - The High court set aside the assessment orders related to the seizure, directing a re-examination in accordance with the Digital Evidence Investigation Manual issued by CBDT, highlighting that such procedures are mandatory and not optional.
Procedure of Conducting the search and seizure of the digital data from the premises of the petitioner - seizure of the .txt files from an undisclosed location - Digital Evidence Investigation Manual - The High court set aside the assessment orders related to the seizure, directing a re-examination in accordance with the Digital Evidence Investigation Manual issued by CBDT, highlighting that such procedures are mandatory and not optional.
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