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 under section 2(22)(e) - Payment for public issue - mere repayment of money borrowed by the share holder will not escape him from the provisions of sec. 2(22)(e) of the Act. - AT
Deemed dividend under section 2(22)(e) - Payment for public issue - mere repayment of money borrowed by the share holder will not escape him from the provisions of sec. 2(22)(e) of the Act. - AT
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