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 under the Explanation under sub-section (4A) of section 80HHC - assessee is exporting directly to the buyers and also through export houses - submission of revenue that the premium earned by the respondent assessee is totally unrelated to export is fallacious - SC
Disallowance under the Explanation under sub-section (4A) of section 80HHC - assessee is exporting directly to the buyers and also through export houses - submission of revenue that the premium earned by the respondent assessee is totally unrelated to export is fallacious - SC
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