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...
Addition on account of notional rent u/s. 23(1)(a) - no addition on account of notional deemed rent u/s.23(1)(a) can be made, once the property itself was either in the stage of construction or was not ready for use.
Addition on account of notional rent u/s. 23(1)(a) - no addition on account of notional deemed rent u/s.23(1)(a) can be made, once the property itself was either in the stage of construction or was not ready for use.
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