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...
Addition u/s 36(1)(iii) - advanced interest bearing fund without charging any interest to its associate concerns - Whether it is commercially expedient or not for the Assessee cannot be decided by the Revenue authorities unless a decision taken by the Assessee can be held to be arbitrary or motivated, deliberately taken to defeat the purpose of the revenue
Addition u/s 36(1)(iii) - advanced interest bearing fund without charging any interest to its associate concerns - Whether it is commercially expedient or not for the Assessee cannot be decided by the Revenue authorities unless a decision taken by the Assessee can be held to be arbitrary or motivated, deliberately taken to defeat the purpose of the revenue
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