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...
Addition in the hands of the assessee was made on protective basis which means the AO himself was not confident with respect to the tax liability of the alleged income estimated by him in the hands of the assessee - Additions made by AO deleted - AT
Addition in the hands of the assessee was made on protective basis which means the AO himself was not confident with respect to the tax liability of the alleged income estimated by him in the hands of the assessee - Additions made by AO deleted - AT
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