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 on account of interest - capital expenditure or revenue expenditure - assessee has "parked its investible funds in the equity shares of a closely associated concern" - there was no basis for treating the interest expenditure claimed by the assessee as capital expenditure - AT
Addition on account of interest - capital expenditure or revenue expenditure - assessee has "parked its investible funds in the equity shares of a closely associated concern" - there was no basis for treating the interest expenditure claimed by the assessee as capital expenditure - AT
Note: It is a system-generated summary and is for quick reference only.
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