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...
Deemed dividend u/s 2(22)(e) - amount received by the assessee from his father - family settlement - transfer of money from father to son is nothing unusual - The observation of AO that the agreement is artificially created for the purpose of withdrawing money by the assessee from the accumulated profits of MEL is not maintainable.
Deemed dividend u/s 2(22)(e) - amount received by the assessee from his father - family settlement - transfer of money from father to son is nothing unusual - The observation of AO that the agreement is artificially created for the purpose of withdrawing money by the assessee from the accumulated profits of MEL is not maintainable.
Note: It is a system-generated summary and is for quick reference only.
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