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...
Accrual of interest income - FDRs made in the name of the respondent-assessee by virtue of a consensual order passed by the Arbitral Tribunal - till the final award was passed by the Arbitral Tribunal determining the ownership of the fixed deposits and interest, it could not be said that the interest income had crystallized in the respondent’s hands - HC
Accrual of interest income - FDRs made in the name of the respondent-assessee by virtue of a consensual order passed by the Arbitral Tribunal - till the final award was passed by the Arbitral Tribunal determining the ownership of the fixed deposits and interest, it could not be said that the interest income had crystallized in the respondent’s hands - HC
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