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...
Disallowance of increase in salary of directors - AO was not convinced that the increase in turnover is only because of efforts of the Director - Revenue authorities in this case are trying to enter into the shoes of the businessman, which is not permissible.
Disallowance of increase in salary of directors - AO was not convinced that the increase in turnover is only because of efforts of the Director - Revenue authorities in this case are trying to enter into the shoes of the businessman, which is not permissible.
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