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...
Addition u/s 41(1) – Revenue's case is that there was no genuine trading liability incurred by the assessee. Question of remission or cessation thereof would not arise - No addition - HC
Addition u/s 41(1) – Revenue's case is that there was no genuine trading liability incurred by the assessee. Question of remission or cessation thereof would not arise - No addition - HC
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