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...
Rejection of books result - estimation of NP @5% of gross contractual receipts - assessee firm is entitled for separate deduction of depreciation, interest and salary payment to partners - AT
Rejection of books result - estimation of NP @5% of gross contractual receipts - assessee firm is entitled for separate deduction of depreciation, interest and salary payment to partners - AT
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