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 u/s 14A - There is direct and proximate nexus between the exempted income, which the investments shall genearate and the expenditures directly or indirectly involved in earning the said income
Disallowance u/s 14A - There is direct and proximate nexus between the exempted income, which the investments shall genearate and the expenditures directly or indirectly involved in earning the said income
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