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...
As per section 143(1) - denial of exemption u/s 54F while processing rectification application u/s 154 for claim of TDS - such an enquiry is not possible on the petition filed by the assessee under Section 154 - AT
As per section 143(1) - denial of exemption u/s 54F while processing rectification application u/s 154 for claim of TDS - such an enquiry is not possible on the petition filed by the assessee under Section 154 - AT
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