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...
Levy of interest u/s 234B and u/s 234C - MAT - Book Adjustments - Section 115J/115JA - assessee cannot seek to escape the mandatory levy being fastened on it under the plea that it had bona fide belief that it is not liable - AT
Levy of interest u/s 234B and u/s 234C - MAT - Book Adjustments - Section 115J/115JA - assessee cannot seek to escape the mandatory levy being fastened on it under the plea that it had bona fide belief that it is not liable - AT
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