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...
Taxability pertaining to retention money - Whether income did accrue or not would depend on the fact whether the right to receive said amount had accrued or not - Merely whether tax was deductible or not would not decide the taxability of certain receipts - HC
Taxability pertaining to retention money - Whether income did accrue or not would depend on the fact whether the right to receive said amount had accrued or not - Merely whether tax was deductible or not would not decide the taxability of certain receipts - HC
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