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...
Income attribution to trust - invoking section 61 - income taxable in the hands of the beneficiaries OR trust - revocable trust or not - Tribunal was perfectly justified in invoking Section 62(2) of the Act read with Section 61(1)
Income attribution to trust - invoking section 61 - income taxable in the hands of the beneficiaries OR trust - revocable trust or not - Tribunal was perfectly justified in invoking Section 62(2) of the Act read with Section 61(1)
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