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...
Disallowance of deferred revenue expenditure in the aggregate incurred towards the product development - AO is correct in disallowing only the expenditure not relatable to the relevant assessment year. - HC
Disallowance of deferred revenue expenditure in the aggregate incurred towards the product development - AO is correct in disallowing only the expenditure not relatable to the relevant assessment year. - HC
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