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...
Expenses on prototype development expenses u/s 36(1)(iv) - Revenue or Capital expenses - The test of enduring benefit is not a certain or conclusive test and it cannot be applied blindly and mechanically - HC
Expenses on prototype development expenses u/s 36(1)(iv) - Revenue or Capital expenses - The test of enduring benefit is not a certain or conclusive test and it cannot be applied blindly and mechanically - HC
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