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...
Assessment orders quashed due to petitioner's illness, remanded for fresh orders. Petitioner directed to file consolidated reply within 30 days. Cases remitted to respondent to pass fresh orders on merits and in accordance with law after considering petitioner's reply and medical condition. Petitioner had not replied to show cause notices, citing kidney ailment treatment. Impugned orders treated as addendum to show cause notices.
Assessment orders quashed due to petitioner's illness, remanded for fresh orders. Petitioner directed to file consolidated reply within 30 days. Cases remitted to respondent to pass fresh orders on merits and in accordance with law after considering petitioner's reply and medical condition. Petitioner had not replied to show cause notices, citing kidney ailment treatment. Impugned orders treated as addendum to show cause notices.
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