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...
Pending disposal of stay petition or appeal, whichever is earlier, by appellate authority, recovery proceedings against appellant for recovery of confirmed amounts shall be kept in abeyance. Application for early hearing of appeal shall be considered by appellate authority. Impugned judgment modified to this limited extent, rest of directions unaltered.
Pending disposal of stay petition or appeal, whichever is earlier, by appellate authority, recovery proceedings against appellant for recovery of confirmed amounts shall be kept in abeyance. Application for early hearing of appeal shall be considered by appellate authority. Impugned judgment modified to this limited extent, rest of directions unaltered.
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