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...
Non-compete fees - whether classifiable u/s 17 of the Act as profits in lieu of salary? - AO observed that payment for noncompete fees with Grasim is only a camouflage - Additions confirmed - HC
Non-compete fees - whether classifiable u/s 17 of the Act as profits in lieu of salary? - AO observed that payment for noncompete fees with Grasim is only a camouflage - Additions confirmed - HC
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