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...
Rectification of mistake u/s 154 - withdrawing the interest granted to the assessee u/s. 244A - as it is noticed that the AO is not the authority who could attribute the delay in the issuance of the refund u/s 244A(2) as also on the ground that the issue is highly debatable issue, we are of the view that the order passed u/s. 154 is unsustainable - AT
Rectification of mistake u/s 154 - withdrawing the interest granted to the assessee u/s. 244A - as it is noticed that the AO is not the authority who could attribute the delay in the issuance of the refund u/s 244A(2) as also on the ground that the issue is highly debatable issue, we are of the view that the order passed u/s. 154 is unsustainable - AT
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