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 41(1) - The Department having accepted the balances outstanding in the previous year, it was not open by Ld. CIT(A) to confirm the addition on the ground that assessee could not prove the genuineness of the said transactions which were undertaken. - AT
Addition u/s 41(1) - The Department having accepted the balances outstanding in the previous year, it was not open by Ld. CIT(A) to confirm the addition on the ground that assessee could not prove the genuineness of the said transactions which were undertaken. - AT
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