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...
Deemed dividend u/s.2(22)(e) - a business transaction between two concerns, under which amount is transferred from one to another cannot be treated as dividend in the hands of shareholder by applying the deeming provisions of section 2(22)(e) - AT
Deemed dividend u/s.2(22)(e) - a business transaction between two concerns, under which amount is transferred from one to another cannot be treated as dividend in the hands of shareholder by applying the deeming provisions of section 2(22)(e) - AT
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