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...
Defective show cause notice lacking minimum details to establish adverse material received post specified date. Cancellation of registration and order-in-original set aside by High Court due to violation of principles of natural justice. Petition disposed, allowing opportunity for issuance of appropriate show cause notice to meet ends of justice.
Defective show cause notice lacking minimum details to establish adverse material received post specified date. Cancellation of registration and order-in-original set aside by High Court due to violation of principles of natural justice. Petition disposed, allowing opportunity for issuance of appropriate show cause notice to meet ends of justice.
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