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 of purchases u/s 40(A)(3) - cash payment exceeding ₹ 20,000/- the genuineness of the transactions being free from vice of any device of evasion of tax is relevant consideration - No additions - AT
Disallowance of purchases u/s 40(A)(3) - cash payment exceeding ₹ 20,000/- the genuineness of the transactions being free from vice of any device of evasion of tax is relevant consideration - No additions - AT
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