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...
Validity of notice u/s 148 – Assessment can not be reopened merely because credit of TDS given and income was not offered to tax since it is not any allowance or deduction or loss or relief - HC
Validity of notice u/s 148 – Assessment can not be reopened merely because credit of TDS given and income was not offered to tax since it is not any allowance or deduction or loss or relief - HC
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