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...
Personal expenses - whether can be taxed in the hands of assessee u/s 2 (24)(iv) as the amount was routed through the franchisee, which was the HUF of the assessee - remand order by ITAT is perfectly justified. - HC
Personal expenses - whether can be taxed in the hands of assessee u/s 2 (24)(iv) as the amount was routed through the franchisee, which was the HUF of the assessee - remand order by ITAT is perfectly justified. - HC
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