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...
Prosecution u/s 276-C(1) & 277 - revenue sought additional witness and additional documents - there is no basis to come to a conclusion that respondent (revenue) is adopting dilatory tactics or is in any way harassing petitioner assessee - production of additional witness/documents on record is permissible.
Prosecution u/s 276-C(1) & 277 - revenue sought additional witness and additional documents - there is no basis to come to a conclusion that respondent (revenue) is adopting dilatory tactics or is in any way harassing petitioner assessee - production of additional witness/documents on record is permissible.
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