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...
Transaction of shares - nature of income - business income or capital gain - magnitude of transactions carried out by the assessee in our view should not be very material in coming to the conclusion that income in question is income from business. - AT
Transaction of shares - nature of income - business income or capital gain - magnitude of transactions carried out by the assessee in our view should not be very material in coming to the conclusion that income in question is income from business. - AT
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