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...
Membership of the private company exceeded 50 or not - Deemed public company - The number of members of the compnay has not exceeded 50 by virtue of transfer of shares by the appellant (singly) to the appellant jointly with his children and wife - HC
Membership of the private company exceeded 50 or not - Deemed public company - The number of members of the compnay has not exceeded 50 by virtue of transfer of shares by the appellant (singly) to the appellant jointly with his children and wife - HC
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