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...
Protective assessment u/s 143(3) r.w.s 153C - since the AO has made the addition substantively in the hands of HUF, in the year 2009-10 and there was no ambiguity in the mind of the assessing officer with regard to the beneficiary, there is no case for making the protective assessment.
Protective assessment u/s 143(3) r.w.s 153C - since the AO has made the addition substantively in the hands of HUF, in the year 2009-10 and there was no ambiguity in the mind of the assessing officer with regard to the beneficiary, there is no case for making the protective assessment.
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