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...
Interest Expenditure - Since, no addition has been made on account of unexplained credit of loan in the earlier year under section 68, then no disallowance can be made out of interest in the present year - AT
Interest Expenditure - Since, no addition has been made on account of unexplained credit of loan in the earlier year under section 68, then no disallowance can be made out of interest in the present year - AT
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