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...
Accrual of income - income can be said to accrue only when it becomes due and must be accompanied by corresponding liability of the other party to pay the amount and only then it can be said that for the purpose of income-tax that the income has accrued to the assessee - AT
Accrual of income - income can be said to accrue only when it becomes due and must be accompanied by corresponding liability of the other party to pay the amount and only then it can be said that for the purpose of income-tax that the income has accrued to the assessee - AT
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