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...
Income from other sources u/s 56 - purchase was lower than the ready reckoner rate - difference between value declared and value as per stamp value authority is less than 10% - The enhancement of tolerance limit from 5% to 10% under Section 50C so as to 56(vii)(b) would be applicable retrospectively - AT
Income from other sources u/s 56 - purchase was lower than the ready reckoner rate - difference between value declared and value as per stamp value authority is less than 10% - The enhancement of tolerance limit from 5% to 10% under Section 50C so as to 56(vii)(b) would be applicable retrospectively - AT
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