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...
Deduction u/s 80IB - Delayed filing of return u/s 139(4) - Power to condone the delay in filing return - vires of Section 80-AC - Assessee directed to make application before CBDT - HC
Deduction u/s 80IB - Delayed filing of return u/s 139(4) - Power to condone the delay in filing return - vires of Section 80-AC - Assessee directed to make application before CBDT - HC
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