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...
Rectification u/s 154 – FBT - as the taxability or otherwise of an ESOP expenditure u/s 115WB(1)(a) is highly debatable issue and such issue cannot be adjudicated in the proceedings u/s 154 - AT
Rectification u/s 154 – FBT - as the taxability or otherwise of an ESOP expenditure u/s 115WB(1)(a) is highly debatable issue and such issue cannot be adjudicated in the proceedings u/s 154 - AT
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