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...
Maintainability of the appeal u/s 260A before HC whereas the rectification application u/s 254(2) is pending before the ITAT - there are substantial questions of law to be decided, hence pendency of a petition for rectification u/s 254(2) can have no impact - appeal is maintainable.
Maintainability of the appeal u/s 260A before HC whereas the rectification application u/s 254(2) is pending before the ITAT - there are substantial questions of law to be decided, hence pendency of a petition for rectification u/s 254(2) can have no impact - appeal is maintainable.
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