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...
Deletion of perquisite u/s 2(24)(vi) - interest free loan to director - interest free money in the form of entrance fee and membership fee available with the company was more than the advance received by the assessee from the said company - No addition - AT
Deletion of perquisite u/s 2(24)(vi) - interest free loan to director - interest free money in the form of entrance fee and membership fee available with the company was more than the advance received by the assessee from the said company - No addition - AT
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