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...
Condonation of delay u/s 119(2)(b)in filing return of income - ruling from the ARA was sought for taxability of income in India which received after due date of filing of return - delay condoned subject to costs
Condonation of delay u/s 119(2)(b)in filing return of income - ruling from the ARA was sought for taxability of income in India which received after due date of filing of return - delay condoned subject to costs
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