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 220(2) - Once the Tribunal’s order is vacated and the original order is revived, the original demand that remained unpaid also gets revived. - charging interest u/s.220(2) of the Act for the entire period from the date of original demand notice till the time when the order giving effect to the Hon'ble High Court of Karnataka was passed. is correct - AT
Levy of interest u/s 220(2) - Once the Tribunal’s order is vacated and the original order is revived, the original demand that remained unpaid also gets revived. - charging interest u/s.220(2) of the Act for the entire period from the date of original demand notice till the time when the order giving effect to the Hon'ble High Court of Karnataka was passed. is correct - AT
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