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 u/s 14A - Whether the provisions of section 14A are applicable even when no exempt income is earned? - Recently, the Hon'ble Supreme Court has dismissed the SLP filed against the decision of the High Court wherein it was held that section 14A of Act cannot be invoked where no exempt income was earned in the relevant year. - AT
Addition u/s 14A - Whether the provisions of section 14A are applicable even when no exempt income is earned? - Recently, the Hon'ble Supreme Court has dismissed the SLP filed against the decision of the High Court wherein it was held that section 14A of Act cannot be invoked where no exempt income was earned in the relevant year. - AT
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