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...
Unexplained credit u/s. 68 - addition of share premium being in excess of NAV and balance excepted - section 56(2)(viia) and (viib) are not applicable to the instant assessment year i.e. 2011-12 and applicable only for the assessment year 2013-14 - no addition
Unexplained credit u/s. 68 - addition of share premium being in excess of NAV and balance excepted - section 56(2)(viia) and (viib) are not applicable to the instant assessment year i.e. 2011-12 and applicable only for the assessment year 2013-14 - no addition
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