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...
Interest on refund - Where it is found that no refund has been granted pursuant to intimation u/s 143(1), the assessee shall be granted relief from such levy of interest u/s 234D and consequentially, levy of interest u/s 220(2) will also undergo a change and the Assessing officer is directed to recompute the interest u/s 220(2) after granting credit for amount paid towards the outstanding taxes instead of interest u/s 234D as done correctly.
Interest on refund - Where it is found that no refund has been granted pursuant to intimation u/s 143(1), the assessee shall be granted relief from such levy of interest u/s 234D and consequentially, levy of interest u/s 220(2) will also undergo a change and the Assessing officer is directed to recompute the interest u/s 220(2) after granting credit for amount paid towards the outstanding taxes instead of interest u/s 234D as done correctly.
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