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...
No disallowance could be made by applying section 40(a)(ia) of the Act in a case where tax was deducted at source under a wrong provision resulting in short deduction of tax. - AT
No disallowance could be made by applying section 40(a)(ia) of the Act in a case where tax was deducted at source under a wrong provision resulting in short deduction of tax. - AT
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