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...
Addition u/s.41(1) - cessation of liability - The onus is on the Assessee to show that year of cessation is different. - addition made in respect of trading liabilities which had ceased to exist represents taxable business income in terms of Section 41(1) of the Act.
Addition u/s.41(1) - cessation of liability - The onus is on the Assessee to show that year of cessation is different. - addition made in respect of trading liabilities which had ceased to exist represents taxable business income in terms of Section 41(1) of the Act.
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