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...
Additions made u/s 69B - excess stock found during survey - assessee contended that as per the books during the course of survey was without the opening stock - no merit - additions confirmed - HC
Additions made u/s 69B - excess stock found during survey - assessee contended that as per the books during the course of survey was without the opening stock - no merit - additions confirmed - HC
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