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...
Computation of interest u/s 234C - i it is pertinent to note that section 234C refers to the term “returned income” in comparison to section 234B which refers to the term “assessed tax” for imposing interest. - AO directed to compute the interest u/s 234C on the “returned income” of the assessee. - AT
Computation of interest u/s 234C - i it is pertinent to note that section 234C refers to the term “returned income” in comparison to section 234B which refers to the term “assessed tax” for imposing interest. - AO directed to compute the interest u/s 234C on the “returned income” of the assessee. - AT
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