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...
LTCG - valuation - reference could be made to DVO only if the value declared by the assessee is in the opinion of AO less than its fair market value - in this case FMV as on 1.4.1981 is more - Reference to DVO is not correct - AT
LTCG - valuation - reference could be made to DVO only if the value declared by the assessee is in the opinion of AO less than its fair market value - in this case FMV as on 1.4.1981 is more - Reference to DVO is not correct - AT
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