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...
Transfer of TDRs amounts to transfer of a Capital Asset - taxing under the head capital gain cannot be sustained as there is no cost of acquisition - provisions of section 55(2) do not apply - AT
Transfer of TDRs amounts to transfer of a Capital Asset - taxing under the head capital gain cannot be sustained as there is no cost of acquisition - provisions of section 55(2) do not apply - AT
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