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...
Reconciliation of the difference between receipts as per TDS Certificates (26AS) and receipts disclosed by the assessee - the explanation put forth by the assessee in an attempt to reconcile the difference in the receipts / turnover declared in the profit and loss account vis-à-vis the receipts/turnover in the TDS Certificates, is unacceptable - AT
Reconciliation of the difference between receipts as per TDS Certificates (26AS) and receipts disclosed by the assessee - the explanation put forth by the assessee in an attempt to reconcile the difference in the receipts / turnover declared in the profit and loss account vis-à-vis the receipts/turnover in the TDS Certificates, is unacceptable - AT
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