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...
Undisclosed investment - Addition on the basis of documents (MoU) seized during the course of search / survey - sale deeds for lands covered by MoUs had not been executed - it was absolutely illegal for the Assessing Officer to presume the factum of payment for those lands and that too at the rate mentioned in the MoUs. - HC
Undisclosed investment - Addition on the basis of documents (MoU) seized during the course of search / survey - sale deeds for lands covered by MoUs had not been executed - it was absolutely illegal for the Assessing Officer to presume the factum of payment for those lands and that too at the rate mentioned in the MoUs. - HC
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