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...
Disallowance of loss claimed - sale of shares - It is quite difficult for the assessee to comment on the nature of the evidence collected from the NSE, because according to the assessee it has carried out the transactions through broker. Now, if some ambiguity has come on the record, such ambiguity could be explained by the broker - AO to re-adjudicate the issue - AT
Disallowance of loss claimed - sale of shares - It is quite difficult for the assessee to comment on the nature of the evidence collected from the NSE, because according to the assessee it has carried out the transactions through broker. Now, if some ambiguity has come on the record, such ambiguity could be explained by the broker - AO to re-adjudicate the issue - AT
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