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...
Bank attachment order set aside due to lack of opportunity for personal hearing, violating natural justice principles. Order remanded for fresh consideration after petitioner pays 10% of disputed tax within 4 weeks. Petition allowed on remand.
Bank attachment order set aside due to lack of opportunity for personal hearing, violating natural justice principles. Order remanded for fresh consideration after petitioner pays 10% of disputed tax within 4 weeks. Petition allowed on remand.
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