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...
Whether interest u/s 234A, 234B, and 234C be charged on notional income - No interest can be charged when there is no real income - The interest will have to be charged in the year when income was earned - HC
Whether interest u/s 234A, 234B, and 234C be charged on notional income - No interest can be charged when there is no real income - The interest will have to be charged in the year when income was earned - HC
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