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...
Before making disallowance u/s 40(a)(ia), the pre-requisite conditions are that the AO should bring material on record to show that the assessee was liable to deduct tax in respect of the expenditure specified in that section - AT
Before making disallowance u/s 40(a)(ia), the pre-requisite conditions are that the AO should bring material on record to show that the assessee was liable to deduct tax in respect of the expenditure specified in that section - AT
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