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 U/s 40A(3) - book entries in respect of incentives. - Merely because some book entries are routed through the assessee’s cash book the learned Assessing Officer cannot ignore the real nature of the transactions and arbitrarily hold them as cash payments - AT
Addition U/s 40A(3) - book entries in respect of incentives. - Merely because some book entries are routed through the assessee’s cash book the learned Assessing Officer cannot ignore the real nature of the transactions and arbitrarily hold them as cash payments - AT
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