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...
Disallowance of interest expenses - assessee has not charged any interest in respect of advance given to the wife of the one of the key personnel of the company - In view of the huge funds available with the assessee without any interest liability, we find that the issue is squarely covered in favour of assessee. - AT
Disallowance of interest expenses - assessee has not charged any interest in respect of advance given to the wife of the one of the key personnel of the company - In view of the huge funds available with the assessee without any interest liability, we find that the issue is squarely covered in favour of assessee. - AT
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