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...
Valuation of closing stock – Addition of proportionate transport charges – adjustment sought to be made is revenue neutral and at best may result in preponement or postponement of revenue - no addition - AT
Valuation of closing stock – Addition of proportionate transport charges – adjustment sought to be made is revenue neutral and at best may result in preponement or postponement of revenue - no addition - AT
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