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 charged u/s 234B - Deposit of amount pursuant to search and seizure proceedings - Provisions of section 132B of the Act governs the manner of utilisation of funds seized by the Department. If the amount seized and kept in PD account is more than the liability payable by assessee, then the assessee is entitled to interest also as per the provisions of section 132B of the Act - this amount cannot be treated as equal and to advance tax for purpose of computing interest u/s 234B - AT
Interest charged u/s 234B - Deposit of amount pursuant to search and seizure proceedings - Provisions of section 132B of the Act governs the manner of utilisation of funds seized by the Department. If the amount seized and kept in PD account is more than the liability payable by assessee, then the assessee is entitled to interest also as per the provisions of section 132B of the Act - this amount cannot be treated as equal and to advance tax for purpose of computing interest u/s 234B - AT
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