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...
Dispute concerns entitlement to interest on delayed refund where the assessing officer denied interest by alleging a lapse in claiming TDS in a revised return. The legal principle stated is that exclusion of any period for calculating interest must be determined by the authority designated under the relevant statute; the AO lacks power to unilaterally disallow interest on that ground. The AO's terse finding was treated as erroneous; the appellate authority accepted the taxpayer's explanation regarding Form 26AS and held there was no lapse in claiming the credit.
Dispute concerns entitlement to interest on delayed refund where the assessing officer denied interest by alleging a lapse in claiming TDS in a revised return. The legal principle stated is that exclusion of any period for calculating interest must be determined by the authority designated under the relevant statute; the AO lacks power to unilaterally disallow interest on that ground. The AO's terse finding was treated as erroneous; the appellate authority accepted the taxpayer's explanation regarding Form 26AS and held there was no lapse in claiming the credit.
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