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...
Excess provision claim under the heads consultancy charges - During the negotiations with the parties the provision was made on the basis of original claim made by the parties - held as ascertained liability - deduction allowed - HC
Excess provision claim under the heads consultancy charges - During the negotiations with the parties the provision was made on the basis of original claim made by the parties - held as ascertained liability - deduction allowed - HC
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