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...
Impugned order quashed, case remitted to pass fresh orders subject to petitioner depositing disputed tax amount. Impugned order treated as addendum to preceding show cause notice. Writ petition allowed, granting partial relief by providing opportunity to explain case after failure to notice hearing notices earlier, remedying time-barred appellate recourse.
Impugned order quashed, case remitted to pass fresh orders subject to petitioner depositing disputed tax amount. Impugned order treated as addendum to preceding show cause notice. Writ petition allowed, granting partial relief by providing opportunity to explain case after failure to notice hearing notices earlier, remedying time-barred appellate recourse.
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