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...
Brought forward losses of firm - covered u/s 187 OR u/s. 78 - change in the terms and conditions of the partnership - the reconstitution of the partnership was made only as a result of changes in the profit sharing ratio amongst the partners - CIT(A) has rightly allowed carry forward losses to be set off, as claimed by the assessee - AT
Brought forward losses of firm - covered u/s 187 OR u/s. 78 - change in the terms and conditions of the partnership - the reconstitution of the partnership was made only as a result of changes in the profit sharing ratio amongst the partners - CIT(A) has rightly allowed carry forward losses to be set off, as claimed by the assessee - AT
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