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 benefit under Section 10(20) - When even respondent/Assessee never claimed the benefit under Section 10(20) of the Income Tax Act, 1961, the High Court is not justified in dismissing the appeals by granting the benefit to the respondent/Assessee under Section 10(20) of the IT Act. - SC
Grant of benefit under Section 10(20) - When even respondent/Assessee never claimed the benefit under Section 10(20) of the Income Tax Act, 1961, the High Court is not justified in dismissing the appeals by granting the benefit to the respondent/Assessee under Section 10(20) of the IT Act. - SC
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