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 u/s 40(a)(ia) - the amount paid by the purchaser on account delay in payment of sale price also constitutes a component of sale price and is a part of sale consideration - No TDS required to be deducted - AT
Addition u/s 40(a)(ia) - the amount paid by the purchaser on account delay in payment of sale price also constitutes a component of sale price and is a part of sale consideration - No TDS required to be deducted - AT
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