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...
Deemed dividend addition u/s 2(22)(e) - computation of accumulated profits - it shall not include current year’s proportionate profit, since the current years profit shall be deemed to accrue only when the books of account are closed at the year end - AT
Deemed dividend addition u/s 2(22)(e) - computation of accumulated profits - it shall not include current year’s proportionate profit, since the current years profit shall be deemed to accrue only when the books of account are closed at the year end - AT
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