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 u/s 40A(2)(b) - AO was not justified in adopting disallowance to the extent of 10% payment under Section 40A(2)(b) of the Act solely on the ground that the company to whom the payment was made, was run by the wife of the Director of the assessee company - HC
Disallowance u/s 40A(2)(b) - AO was not justified in adopting disallowance to the extent of 10% payment under Section 40A(2)(b) of the Act solely on the ground that the company to whom the payment was made, was run by the wife of the Director of the assessee company - HC
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