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 insurance premium on directors life - it is not a business expenditure of the assessee company particularly when the assessee does not consider it as a perquisite in the hands of the concerned director - AT
Disallowance of insurance premium on directors life - it is not a business expenditure of the assessee company particularly when the assessee does not consider it as a perquisite in the hands of the concerned director - AT
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