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 of cash credit u/s 68 – There is a time gap of near about 5 years, the share applicant might have changed their addresses, which could be verified from the ROC by the AO to substantiate his findings, which has not been done by him - matter remanded back - AT
Addition of cash credit u/s 68 – There is a time gap of near about 5 years, the share applicant might have changed their addresses, which could be verified from the ROC by the AO to substantiate his findings, which has not been done by him - matter remanded back - AT
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