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 out of salary and commission paid – AO was right in proportionate allocation of salary paid to the directors on the basis of turnover of both the companies - AT
Disallowance out of salary and commission paid – AO was right in proportionate allocation of salary paid to the directors on the basis of turnover of both the companies - AT
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