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...
Inclusion of AY in which search was conducted into the period of 6 assessment years - recording of satisfaction during the next year - assessment for assessment year 2008-09 should have been completed u/s 153A read with 153C and not as regular assessment u/s 143(3), by treating the A.Y. 2008-09 as year of search. - AT
Inclusion of AY in which search was conducted into the period of 6 assessment years - recording of satisfaction during the next year - assessment for assessment year 2008-09 should have been completed u/s 153A read with 153C and not as regular assessment u/s 143(3), by treating the A.Y. 2008-09 as year of search. - AT
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