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...
Deemed dividend u/s 2(22)(e) - Advance against sales - the payments received by the assessee from AIL are receipt against sales made during the course of commercial transactions and therefore, provision of Section 2(22)(e) is not applicable. - AT
Deemed dividend u/s 2(22)(e) - Advance against sales - the payments received by the assessee from AIL are receipt against sales made during the course of commercial transactions and therefore, provision of Section 2(22)(e) is not applicable. - AT
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