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...
Interest u/s 234B - no direction had actually been given in the assessment order for payment of interest - Form I.T.N.S.150 contained a calculation of interest payable on the tax assessed - this Form must be treated as part of the assessment order in the wider sense - levy of interest confirmed - SC
Interest u/s 234B - no direction had actually been given in the assessment order for payment of interest - Form I.T.N.S.150 contained a calculation of interest payable on the tax assessed - this Form must be treated as part of the assessment order in the wider sense - levy of interest confirmed - SC
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