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...
Sale proceeds realized over and above the cost of asset cannot be categorized as business income under commercial principles rather it represents capital receipt - AT
Sale proceeds realized over and above the cost of asset cannot be categorized as business income under commercial principles rather it represents capital receipt - AT
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