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...
Disallowance of interest expense - loan and advances to sister concerns – Held that:- Rate of interest for advancing the loan to the sister concern was 6% and borrowing in the majority cases was at 12% - no disallowance - HC
Disallowance of interest expense - loan and advances to sister concerns – Held that:- Rate of interest for advancing the loan to the sister concern was 6% and borrowing in the majority cases was at 12% - no disallowance - HC
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