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...
Deemed dividend u/s 2(22)(e) - load & advanced to the shareholders in the guise of share application money to the another concern / company - the dividend income is taxable in the hands of shareholders and not in the hands of the concern. - AT
Deemed dividend u/s 2(22)(e) - load & advanced to the shareholders in the guise of share application money to the another concern / company - the dividend income is taxable in the hands of shareholders and not in the hands of the concern. - AT
Note: It is a system-generated summary and is for quick reference only.
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