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...
Interest on excess tax collected – u/s 244/a - the assessment proceedings didn’t got delayed due to the assessee's failure to submit the details before the authorities – interest allowed from the date of payment of tax - AT
Interest on excess tax collected – u/s 244/a - the assessment proceedings didn’t got delayed due to the assessee's failure to submit the details before the authorities – interest allowed from the date of payment of tax - AT
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