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...
Exemption / deduction u/s 10A - If the assessee’s contention is accepted, it would make section 10A a deduction provision for the A.Y. 2002-03 and an exemption provision for the A.Y. 2003-04, which is manifestly impermissible - AT
Exemption / deduction u/s 10A - If the assessee’s contention is accepted, it would make section 10A a deduction provision for the A.Y. 2002-03 and an exemption provision for the A.Y. 2003-04, which is manifestly impermissible - AT
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