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 u/s 41 - conversion of unsecured loan from the sister as gift by book entry - in the earlier years, interest paid to sister was claimed as deduction - whether remission / cessation of liability u/s 41(1) - Held No - AT
Addition u/s 41 - conversion of unsecured loan from the sister as gift by book entry - in the earlier years, interest paid to sister was claimed as deduction - whether remission / cessation of liability u/s 41(1) - Held No - AT
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