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...
Addition on account of fall in GP - The AO has not invoked section 145(3) in its terms - Therefore, fall in G.P. rate cannot be made a reason for involving section 145(3) - AT
Addition on account of fall in GP - The AO has not invoked section 145(3) in its terms - Therefore, fall in G.P. rate cannot be made a reason for involving section 145(3) - AT
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