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...
Accrual of income - Selection of year of assessment - the entire sum was received upfront in the year in question and TDS was also deducted on that basis - ITAT erred in concluding that the sum received in each of the AYs in question could be spread over five years on the basis of the subsequent agreements - HC
Accrual of income - Selection of year of assessment - the entire sum was received upfront in the year in question and TDS was also deducted on that basis - ITAT erred in concluding that the sum received in each of the AYs in question could be spread over five years on the basis of the subsequent agreements - HC
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