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...
Adjustment of refunds granted for computing of interest u/s 244A - the manner in which the assessing officer has adjusted the refund is not correct and that the assessee would be entitled for interest on the unpaid refunds in accordance with the principle laid out in the aforesaid decision of Tribunal. AO is directed to compute interest under section 244A as per the claim of the assessee after giving a proper opportunity of being heard. - AT
Adjustment of refunds granted for computing of interest u/s 244A - the manner in which the assessing officer has adjusted the refund is not correct and that the assessee would be entitled for interest on the unpaid refunds in accordance with the principle laid out in the aforesaid decision of Tribunal. AO is directed to compute interest under section 244A as per the claim of the assessee after giving a proper opportunity of being heard. - AT
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