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...
Exemption u/s 11 & 12 - the dominant motive in this case is not earning profit but to do charity in the form of public service by providing accommodation to the common man at affordable rates - proviso to section 2(15) is not attracted - exemption allowed - AT
Exemption u/s 11 & 12 - the dominant motive in this case is not earning profit but to do charity in the form of public service by providing accommodation to the common man at affordable rates - proviso to section 2(15) is not attracted - exemption allowed - AT
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