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...
Exemption u/s 11- taxability of unregistered trust - AO has brought gross receipts to tax which is against the basic tenets of law where only the real income which is determined after deducting expenses from gross receipts i.e only net income can be brought to tax - remanded AO to examine the claim of the expenditure against the gross receipts
Exemption u/s 11- taxability of unregistered trust - AO has brought gross receipts to tax which is against the basic tenets of law where only the real income which is determined after deducting expenses from gross receipts i.e only net income can be brought to tax - remanded AO to examine the claim of the expenditure against the gross receipts
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