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...
Rectification of mistake u/s 154 - subject income being inadvertently shown under the wrong head - Taxability of income in India - The benefit of Article 121 of India-USA Double Taxation Avoidance Agreement [in short, “Indo-USA DTAA”] was available to the respondent/assessee. - Tribunal rightly allowed the claim of assessee - HC
Rectification of mistake u/s 154 - subject income being inadvertently shown under the wrong head - Taxability of income in India - The benefit of Article 121 of India-USA Double Taxation Avoidance Agreement [in short, “Indo-USA DTAA”] was available to the respondent/assessee. - Tribunal rightly allowed the claim of assessee - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
