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...
Nature of expenses – builders generally offer some amount as compensation against delay in handing over the properties - the nature of payment as compensatory and not penal - AT
Nature of expenses – builders generally offer some amount as compensation against delay in handing over the properties - the nature of payment as compensatory and not penal - AT
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