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...
Correct head of taxability of interest income - business income or income from other sources - the assessee firm had availed overdraft facility from the bank against the pledged of fixed deposit and overdraft amount was used for the purpose of business and interest was paid - since it is inextricably linked with the business activity, the impugned interest income has to be treated as business income
Correct head of taxability of interest income - business income or income from other sources - the assessee firm had availed overdraft facility from the bank against the pledged of fixed deposit and overdraft amount was used for the purpose of business and interest was paid - since it is inextricably linked with the business activity, the impugned interest income has to be treated as business income
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