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...
Waiver of Interest for defaults in payment of advance tax u/s 234B rejected - since the entire amount was not spent the question of any allowable expenses being deducted in computing the income from the profits and gains of the appellant does not arise. - Interest not waived - HC
Waiver of Interest for defaults in payment of advance tax u/s 234B rejected - since the entire amount was not spent the question of any allowable expenses being deducted in computing the income from the profits and gains of the appellant does not arise. - Interest not waived - HC
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