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...
Computation of deduction u/s 10A - exclusion of expenditure incurred in foreign currency in export of software, from the purview of 'Export Turnover' - the artificial split up of the transaction by the Assessing Officer, that too without any materials on his file, is wholly unsustainable
Computation of deduction u/s 10A - exclusion of expenditure incurred in foreign currency in export of software, from the purview of 'Export Turnover' - the artificial split up of the transaction by the Assessing Officer, that too without any materials on his file, is wholly unsustainable
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