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...
Addition u/s 145A - valuation of closing stock - Since CENVAT is not available to the assessee then the enhancing the value of semi finished and finished goods in the closing are not warranted. - AT
Addition u/s 145A - valuation of closing stock - Since CENVAT is not available to the assessee then the enhancing the value of semi finished and finished goods in the closing are not warranted. - AT
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