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 capital expenditure claimed under the head “loan syndication charges” - Since the expenditure has not been claimed by the assessee while computing the income under the head “income from business”, therefore, no disallowance under section 40A(2)(a) can be made - AT
Addition of capital expenditure claimed under the head “loan syndication charges” - Since the expenditure has not been claimed by the assessee while computing the income under the head “income from business”, therefore, no disallowance under section 40A(2)(a) can be made - AT
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