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...
Assessee fails whether the enhancement in its income is considered as on account of a TP adjustment or for denial of deduction u/s. 10A, i.e., from the standpoint of both Explanation 1 or 7 to s. 271(1)(c) – the levy of penalty upheld - AT
Assessee fails whether the enhancement in its income is considered as on account of a TP adjustment or for denial of deduction u/s. 10A, i.e., from the standpoint of both Explanation 1 or 7 to s. 271(1)(c) – the levy of penalty upheld - AT
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