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...
Denial of exemption claim - tribunal has clubbing the three appeal and delivered different decisions - If there was justification for rendering a separate finding in the case of the Petitioner's Appeal, then, in the first instance it is not clear as to why it was clubbed along with other Appeals - HC
Denial of exemption claim - tribunal has clubbing the three appeal and delivered different decisions - If there was justification for rendering a separate finding in the case of the Petitioner's Appeal, then, in the first instance it is not clear as to why it was clubbed along with other Appeals - HC
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