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...
Bogus purchases addition - The only valid argument is that there could be no sales without purchases. But the price at which the goods were purchased remained a grey colour when admittedly the payment was made in cash. As the undisputed fact that the payments were made in cash under section 40A(3) is attracted - AT
Bogus purchases addition - The only valid argument is that there could be no sales without purchases. But the price at which the goods were purchased remained a grey colour when admittedly the payment was made in cash. As the undisputed fact that the payments were made in cash under section 40A(3) is attracted - AT
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