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...
Deduction u/s 10A - Application of section 80IA(10) - claim excess deduction showing excessive (extra ordinary) profit - revenue arising from its oversees Associated Enterprises (AEs) - Whether sec. 80IA(10) applies when the second party to the transaction is a non-resident - held No - AT
Deduction u/s 10A - Application of section 80IA(10) - claim excess deduction showing excessive (extra ordinary) profit - revenue arising from its oversees Associated Enterprises (AEs) - Whether sec. 80IA(10) applies when the second party to the transaction is a non-resident - held No - AT
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