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...
Interest on delayed refund at notified rate of interest (6%) to the appellant - enhanced rate of interest - The Commissioner (Appeals) has relied on the decision of Supreme Court (in another case granting enhanced rate of interest) only to take the view that the appellant is eligible for interest due to delay. This does not mean that an assessee is always eligible for enhanced rate of interest than the notified rate of interest - AT
Interest on delayed refund at notified rate of interest (6%) to the appellant - enhanced rate of interest - The Commissioner (Appeals) has relied on the decision of Supreme Court (in another case granting enhanced rate of interest) only to take the view that the appellant is eligible for interest due to delay. This does not mean that an assessee is always eligible for enhanced rate of interest than the notified rate of interest - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
