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...
Proportionate disallowance of depreciation on computer and software, based on the number of employees of the assessee - keeping extra computer for meeting any emergent situation of non-functional computer or under repair computer is not an unusual practice - No disallowance - AT
Proportionate disallowance of depreciation on computer and software, based on the number of employees of the assessee - keeping extra computer for meeting any emergent situation of non-functional computer or under repair computer is not an unusual practice - No disallowance - AT
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