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...
Disallowance on account of excess claim of managerial remuneration u/s 40A - Even though the appellant company may be deemed as Public Limited Company under the Companies Act, 1956 and had made default under that Act, it could not be the sole reason for making disallowance of managerial remuneration for computing the taxable income of the assessee
Disallowance on account of excess claim of managerial remuneration u/s 40A - Even though the appellant company may be deemed as Public Limited Company under the Companies Act, 1956 and had made default under that Act, it could not be the sole reason for making disallowance of managerial remuneration for computing the taxable income of the assessee
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