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...
Amount mentioned in seized diary, part of consideration or not - Assessment u/s 153C - the action of the Revenue authorities in treating the amount represented by the pronote as well, as part of the consideration on the sale of the property is upheld - AT
Amount mentioned in seized diary, part of consideration or not - Assessment u/s 153C - the action of the Revenue authorities in treating the amount represented by the pronote as well, as part of the consideration on the sale of the property is upheld - AT
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