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 - the explanation of payments on Holidays appears highly doubtful but however such inference cannot be taken in the realm of obvious mistake. Section 154 has no application to gauge the purported mala fides in explanation offered by the Assessee behind such transaction. - AT
Rectification of mistake u/s 154 - the explanation of payments on Holidays appears highly doubtful but however such inference cannot be taken in the realm of obvious mistake. Section 154 has no application to gauge the purported mala fides in explanation offered by the Assessee behind such transaction. - AT
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