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...
Assessment having been made u/s 144 and with clear provisions of section 184(5), the ld. CIT(A) is not justified in allowing interest and salary to the partners - AT
Assessment having been made u/s 144 and with clear provisions of section 184(5), the ld. CIT(A) is not justified in allowing interest and salary to the partners - AT
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