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...
The HC held that the show cause notice u/s 18 was valid, but set aside the notice u/s 28(4) as authorities failed to conduct provisional assessment before issuance. The petitioner was granted six weeks to reply to the Section 18 notice.
The HC held that the show cause notice u/s 18 was valid, but set aside the notice u/s 28(4) as authorities failed to conduct provisional assessment before issuance. The petitioner was granted six weeks to reply to the Section 18 notice.
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