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...
Depreciation - reduction of subsidy from actual cost reduced - though subsidy was held as capital receipt but this cannot be held to be a rule of universal application without examination of relevant facts - HC
Depreciation - reduction of subsidy from actual cost reduced - though subsidy was held as capital receipt but this cannot be held to be a rule of universal application without examination of relevant facts - HC
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