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...
Bright Line Test - Whether ITAT has erred in relying upon the judgment of this Court in Sony Ericsson Mobile Communication [2015 (3) TMI 580 - DELHI HIGH COURT] as the Department has not accepted the decision passed in Sony Ericsson (supra) and has preferred an appeal against the said decision before the Supreme Court - Held No - Revenue appeal dismissed - HC
Bright Line Test - Whether ITAT has erred in relying upon the judgment of this Court in Sony Ericsson Mobile Communication [2015 (3) TMI 580 - DELHI HIGH COURT] as the Department has not accepted the decision passed in Sony Ericsson (supra) and has preferred an appeal against the said decision before the Supreme Court - Held No - Revenue appeal dismissed - HC
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