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...
Deemed income u/s 41(1) - merely relying upon the expression ‘principal’ used in the letter, one cannot conclude that the amount contains only the principal component of loan, and no element of interest is embedded therein. - AT
Deemed income u/s 41(1) - merely relying upon the expression ‘principal’ used in the letter, one cannot conclude that the amount contains only the principal component of loan, and no element of interest is embedded therein. - AT
Note: It is a system-generated summary and is for quick reference only.