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...
Effective date for set up of business – The business of the appellant had been setup as the assessee had acquired the necessary infrastructure and had also started making payment of salary and wages - HC
Effective date for set up of business – The business of the appellant had been setup as the assessee had acquired the necessary infrastructure and had also started making payment of salary and wages - HC
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