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...
Accrual of interest - assessee has not received any amount till date. - No benefit has been received, so no addition can be made on the notional income. However, the department is always at liberty to charge tax as and when the amount will be received by the assessee - HC
Accrual of interest - assessee has not received any amount till date. - No benefit has been received, so no addition can be made on the notional income. However, the department is always at liberty to charge tax as and when the amount will be received by the assessee - HC
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