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 Administrative and Other Expenses as pre-operative expenses – the assessee had successfully identified certain mineral rich blocks too - the expression 'setting up' means 'to place on foot' or to establish or 'to ready to commence' - claim allowed - AT
Disallowance of Administrative and Other Expenses as pre-operative expenses – the assessee had successfully identified certain mineral rich blocks too - the expression 'setting up' means 'to place on foot' or to establish or 'to ready to commence' - claim allowed - AT
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