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...
Excessive shortage in the Sesame seeds account - assessee has failed to quantify the shortage/loss due to substandards material - Considering the smallness of the overall percentage which is 0.86%, the balance of convenience is tilted in favour of the assessee - AT
Excessive shortage in the Sesame seeds account - assessee has failed to quantify the shortage/loss due to substandards material - Considering the smallness of the overall percentage which is 0.86%, the balance of convenience is tilted in favour of the assessee - AT
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