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...
Interpretation of section 92BA(i) read with section 40A(2)(b) - Purchase of loans by the Petitioner from the HDFC Ltd. - the transaction does not fall within the meaning of a SDT as required under section 92BA(i) - not required to be disclosed by the Petitioner by filing Form 3CEB.
Interpretation of section 92BA(i) read with section 40A(2)(b) - Purchase of loans by the Petitioner from the HDFC Ltd. - the transaction does not fall within the meaning of a SDT as required under section 92BA(i) - not required to be disclosed by the Petitioner by filing Form 3CEB.
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