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...
Levy of additional income tax u/s 104(1) - no actual accounting profit - the assessee could not distribute the dividend to it's shareholders. - there is no question of applicability of Section 104 - HC
Levy of additional income tax u/s 104(1) - no actual accounting profit - the assessee could not distribute the dividend to it's shareholders. - there is no question of applicability of Section 104 - HC
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