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...
Club membership fees paid for employees is allowable u/s 37 - assessee has given detailed list of persons for whom the membership is taken. Therefore disallowance of club membership is deleted - AT
Club membership fees paid for employees is allowable u/s 37 - assessee has given detailed list of persons for whom the membership is taken. Therefore disallowance of club membership is deleted - AT
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