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...
Computation of capital gains - determination of cost of acquisition as on April 1, 1974 - Assessing Officer had no jurisdiction to place reliance on the valuation report obtained subsequently and that too when not obtained in exercise of powers u/s 55A - HC
Computation of capital gains - determination of cost of acquisition as on April 1, 1974 - Assessing Officer had no jurisdiction to place reliance on the valuation report obtained subsequently and that too when not obtained in exercise of powers u/s 55A - HC
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