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 Depreciation on Goodwill – The specified intangible assets acquired under slump sale agreement were in the nature of “business or commercial rights of similar nature“ specified in Section 32(1)(ii) of the Act and were accordingly eligible for depreciation - AT
Disallowance of Depreciation on Goodwill – The specified intangible assets acquired under slump sale agreement were in the nature of “business or commercial rights of similar nature“ specified in Section 32(1)(ii) of the Act and were accordingly eligible for depreciation - AT
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