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...
Addition u/s 68 - creditworthiness and the genuineness of the transactions - it is the satisfaction of the Assessing Officer but not of the Commissioner of Income Tax (Appeals) - HC
Addition u/s 68 - creditworthiness and the genuineness of the transactions - it is the satisfaction of the Assessing Officer but not of the Commissioner of Income Tax (Appeals) - HC
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