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...
Disallowance u/s 14A - The claim of the assessee was that no expenditure was incurred for earning exempt income, but once the AO had recorded his satisfaction in terms of sub-section (2), then the disallowance can be made as per Rule 8D(2)(iii) - AT
Disallowance u/s 14A - The claim of the assessee was that no expenditure was incurred for earning exempt income, but once the AO had recorded his satisfaction in terms of sub-section (2), then the disallowance can be made as per Rule 8D(2)(iii) - AT
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