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...
Low net profit ratio - AO has not pointed out any defect or deficiency in the claim of expenditure nor any expenditure has been held as bogus by the AO. AO asked financial results of the last three years and proceeded to make addition in this regard without confronting the issue to the assessee which is not a justified approach. - AT
Low net profit ratio - AO has not pointed out any defect or deficiency in the claim of expenditure nor any expenditure has been held as bogus by the AO. AO asked financial results of the last three years and proceeded to make addition in this regard without confronting the issue to the assessee which is not a justified approach. - AT
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