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...
Disallowance u/s 14A r.w.r. 8D(2)(iii) - it is settled legal position that before proceeding to invoke provisions of Rule 8D of the Rules for computing disallowance u/s 14A AO must express his dissatisfaction regarding the computation of disallowance made by the Assessee. - AT
Disallowance u/s 14A r.w.r. 8D(2)(iii) - it is settled legal position that before proceeding to invoke provisions of Rule 8D of the Rules for computing disallowance u/s 14A AO must express his dissatisfaction regarding the computation of disallowance made by the Assessee. - AT
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