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...
Disallowance of loss on sale of iron ore – AO's objection that there is no physical movement of stocks and it is only an accommodative transaction is incorrect as the iron ore was already mined and transported to the port for the purpose of export - Transaction is not a sham transaction - AT
Disallowance of loss on sale of iron ore – AO's objection that there is no physical movement of stocks and it is only an accommodative transaction is incorrect as the iron ore was already mined and transported to the port for the purpose of export - Transaction is not a sham transaction - AT
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