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...
When the same amount has been surrendered and taxed in the hands of donor then the source of the funds which were used for expenditure as to held as explained in the hands of donee assessee trust and provisions of section 69C cannot be invoked for making addition on account explained expenditure - AT
When the same amount has been surrendered and taxed in the hands of donor then the source of the funds which were used for expenditure as to held as explained in the hands of donee assessee trust and provisions of section 69C cannot be invoked for making addition on account explained expenditure - AT
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