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...
SC directed the respondent department to furnish certified copies of three lost original files (File nos. 11-13), while maintaining all existing legal contentions. For original file nos. 1-10, the department agreed to hand over the documents, with the assessee required to collect them from the concerned department. All pending applications were consequently disposed of, resolving the document retrieval dispute through a balanced procedural approach.
SC directed the respondent department to furnish certified copies of three lost original files (File nos. 11-13), while maintaining all existing legal contentions. For original file nos. 1-10, the department agreed to hand over the documents, with the assessee required to collect them from the concerned department. All pending applications were consequently disposed of, resolving the document retrieval dispute through a balanced procedural approach.
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