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 made on account of purchases from the hawala parties - addition is to be restricted by applying GP rate of 10% on the said purchases over and above the GP rate shown by the assessee. - AT
Bogus purchases - Addition made on account of purchases from the hawala parties - addition is to be restricted by applying GP rate of 10% on the said purchases over and above the GP rate shown by the assessee. - AT
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