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...
Adjustments of interest payable to IFCI and sales tax penalty under section 43B while processing the case under section 143(1)(a) - As the adjustments made by the AO could not be said to be prima facie adjustments, therefore, the additions made in the intimation issued u/s 143(1)(a)were not sustainable - HC
Adjustments of interest payable to IFCI and sales tax penalty under section 43B while processing the case under section 143(1)(a) - As the adjustments made by the AO could not be said to be prima facie adjustments, therefore, the additions made in the intimation issued u/s 143(1)(a)were not sustainable - HC
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