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...
Claim of exemption / deduction during assessment proceedings - Denial of additional claims on the ground that claims were not made by way of filing the revised return under Section 139(5) - claimed allowed - AT
Claim of exemption / deduction during assessment proceedings - Denial of additional claims on the ground that claims were not made by way of filing the revised return under Section 139(5) - claimed allowed - AT
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