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...
Revision u/s 263 by CIT - when transfer price is consonance with the fair market price then conditions of this section gets satisfied. Hence applicability of section 80IA(8) has been examined by the AO - revision order quashed.
Revision u/s 263 by CIT - when transfer price is consonance with the fair market price then conditions of this section gets satisfied. Hence applicability of section 80IA(8) has been examined by the AO - revision order quashed.
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