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...
Addition made u/s 40A(3) - cash payments – There is no prohibition or restriction on a middleman to work as agent of different parties, if he was acting on behalf of the assessee as agent - AT
Addition made u/s 40A(3) - cash payments – There is no prohibition or restriction on a middleman to work as agent of different parties, if he was acting on behalf of the assessee as agent - AT
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