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...
Interest on Refund u/s 244A - inordinate delay in grant of refund - in absence of any specific provisions in the Income tax Act, for allowance of interest on refund or compensation for the delayed period of refund of interest, we are constrained to hold that the appeal of the assessee cannot be allowed.
Interest on Refund u/s 244A - inordinate delay in grant of refund - in absence of any specific provisions in the Income tax Act, for allowance of interest on refund or compensation for the delayed period of refund of interest, we are constrained to hold that the appeal of the assessee cannot be allowed.
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