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...
Grant of interest on refund of amount to the assessee u/s 244A - Interest u/s 220(2) - the finding recorded by the Commissioner as well as the Tribunal that the interest under Section 220(2) of the Act is not chargeable during the period of stay is perverse as the interest is mandatorily leviable under Section 220(2) of the Act. - HC
Grant of interest on refund of amount to the assessee u/s 244A - Interest u/s 220(2) - the finding recorded by the Commissioner as well as the Tribunal that the interest under Section 220(2) of the Act is not chargeable during the period of stay is perverse as the interest is mandatorily leviable under Section 220(2) of the Act. - HC
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