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...
Charging of interest u/s 234A - AO should be specific and clear and the assessee must be made to know that the AO has applied his mind and has ordered charging of interest. - HC
Charging of interest u/s 234A - AO should be specific and clear and the assessee must be made to know that the AO has applied his mind and has ordered charging of interest. - HC
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