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 u/s 153A pursuant to search - estimation of rate of net profit - The net profit rates shown by the appellant in the revised returns are considered as unfair and unreasonable - estimated at 8% - AT
Assessment u/s 153A pursuant to search - estimation of rate of net profit - The net profit rates shown by the appellant in the revised returns are considered as unfair and unreasonable - estimated at 8% - AT
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