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 u/s 234B and 234C - appellant has offered the cash seized as advance tax against the liability in block assessment - tribunal ought to have held the date of payment of tax by the assessee as 15.03.2007 i.e., the date on which the request was made by the assessee to adjust the cash seized against the advance tax payable towards the tax for the Assessment year 2007-08.
Interest u/s 234B and 234C - appellant has offered the cash seized as advance tax against the liability in block assessment - tribunal ought to have held the date of payment of tax by the assessee as 15.03.2007 i.e., the date on which the request was made by the assessee to adjust the cash seized against the advance tax payable towards the tax for the Assessment year 2007-08.
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