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...
Additions u/s 56(2)(viib) r.w.r 11UA on account of undervaluation of shares - fair market value - share price calculated by the assessee of TEPL for ₹ 5 per shares has been determined in accordance with the provision of Rule 11UA - no additions - AT
Additions u/s 56(2)(viib) r.w.r 11UA on account of undervaluation of shares - fair market value - share price calculated by the assessee of TEPL for ₹ 5 per shares has been determined in accordance with the provision of Rule 11UA - no additions - AT
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