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 69 - the income surrendered during the course of survey cannot be brought to tax under the deeming provisions of section 69 and the same has been rightly offered to tax under the head “business income”. - Not liable for higher rate of tax u/s 115BBE i.e. @ 60% - AT
Addition u/s 69 - the income surrendered during the course of survey cannot be brought to tax under the deeming provisions of section 69 and the same has been rightly offered to tax under the head “business income”. - Not liable for higher rate of tax u/s 115BBE i.e. @ 60% - AT
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