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...
Commission paid to director u/s 36(1)(ii) - as a part of remuneration package of the executive director - based on his performance evaluation and also considering his contribution in meeting the financial performance of the company - There is substantial increase in profit before tax as compared to earlier years - duly allowable
Commission paid to director u/s 36(1)(ii) - as a part of remuneration package of the executive director - based on his performance evaluation and also considering his contribution in meeting the financial performance of the company - There is substantial increase in profit before tax as compared to earlier years - duly allowable
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