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...
Presumptive income u/s 44AF of the Income Tax Act – No nexus had been established by the assessee with the sale transaction of their business and cash deposited. Thus, Section 44AF cannot be applied in this case - AT
Presumptive income u/s 44AF of the Income Tax Act – No nexus had been established by the assessee with the sale transaction of their business and cash deposited. Thus, Section 44AF cannot be applied in this case - AT
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