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...
TDS - Non-deduction of tax at source on year end provision - the payee is not identifiable at the time of making of provision and further the entire provision has been written back in the next year - No disallowance - AT
TDS - Non-deduction of tax at source on year end provision - the payee is not identifiable at the time of making of provision and further the entire provision has been written back in the next year - No disallowance - AT
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