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...
Capital gains - Denial of Deduction u/s. 54EC of the Act – investment in REC bonds - payment of the maturity proceeds to any one of the bond holders is not a material factor for deciding the ownership of the bonds - AT
Capital gains - Denial of Deduction u/s. 54EC of the Act – investment in REC bonds - payment of the maturity proceeds to any one of the bond holders is not a material factor for deciding the ownership of the bonds - AT
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