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...
Levy of interest under section 115P - It is not in dispute that dividend tax, under section 115P of the Act, was paid by the assessee well within 14 days of declaration of dividend by the shareholders in the annual general meeting, hence no levy of interest - HC
Levy of interest under section 115P - It is not in dispute that dividend tax, under section 115P of the Act, was paid by the assessee well within 14 days of declaration of dividend by the shareholders in the annual general meeting, hence no levy of interest - HC
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