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...
When on the same set of facts and circumstances of the case, renewal of approval under section 80G(5)(vi) has been granted for earlier years and there being no change in the facts and circumstances in the years for which renewal is sought for, there is no justification to reject the assessee's application for renewal of exemption certificate under section 80G(5)(vi) - AT
When on the same set of facts and circumstances of the case, renewal of approval under section 80G(5)(vi) has been granted for earlier years and there being no change in the facts and circumstances in the years for which renewal is sought for, there is no justification to reject the assessee's application for renewal of exemption certificate under section 80G(5)(vi) - AT
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