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 under Section 41(1) - The loan transactions were on the capital account and the writing off the loan was also on capital account and did not find place in the Profit and Loss Account - Thus the cessation of the liability by itself would not lead to the attraction of Section 41(1) - HC
Addition under Section 41(1) - The loan transactions were on the capital account and the writing off the loan was also on capital account and did not find place in the Profit and Loss Account - Thus the cessation of the liability by itself would not lead to the attraction of Section 41(1) - HC
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