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...
Allowability of Interest expenses @21.3% - unsecured redeemable cumulative non-convertible debentures - AO has compared the rate of interest paid on unsecured redeemable cumulative non-convertible debentures with the rate of interest at which the secured loan was borrowed by the assessee, which is wholly erroneous - However, matter restored back to determining the arm’s length interest rate considering risk and other factors - AT
Allowability of Interest expenses @21.3% - unsecured redeemable cumulative non-convertible debentures - AO has compared the rate of interest paid on unsecured redeemable cumulative non-convertible debentures with the rate of interest at which the secured loan was borrowed by the assessee, which is wholly erroneous - However, matter restored back to determining the arm’s length interest rate considering risk and other factors - AT
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