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 u/s 40(a)(ia) of the Income Tax Act – affluent treatment charges - Whether TDS is deductible u/s 194C or u/s 194J of the Income Tax Act - No TDS u/s 194J - AT
Disallowance u/s 40(a)(ia) of the Income Tax Act – affluent treatment charges - Whether TDS is deductible u/s 194C or u/s 194J of the Income Tax Act - No TDS u/s 194J - AT
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