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...
Nature of loss - "business loss" or "speculative transactions" - what is "hedging transaction" and when it can be a "speculative transaction"? - safeguard against loss through price fluctuation in respect of the contract for actual delivery of the goods manufactured - allowed as business loss - HC
Nature of loss - "business loss" or "speculative transactions" - what is "hedging transaction" and when it can be a "speculative transaction"? - safeguard against loss through price fluctuation in respect of the contract for actual delivery of the goods manufactured - allowed as business loss - HC
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