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...
Deemed dividend u/s 2(22)(e) - assessment in pursuance of search action u/s 132(1) - addition on account of deemed dividend u/s 2(22)(e) deleted as same is beyond the scope of assessment u/s 153A - AT
Deemed dividend u/s 2(22)(e) - assessment in pursuance of search action u/s 132(1) - addition on account of deemed dividend u/s 2(22)(e) deleted as same is beyond the scope of assessment u/s 153A - AT
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