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...
Scheme of amalgamation - notice u/s 142(1) - appointed date v/s effective date - transferor company no longer survives & the question of assessing such company for the purpose of income tax would not possible - HC
Scheme of amalgamation - notice u/s 142(1) - appointed date v/s effective date - transferor company no longer survives & the question of assessing such company for the purpose of income tax would not possible - HC
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