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...
Assessment of trust as AOP - exclusion of Corpus funds - all the voluntary contributions received by the assessee are taxable within the meaning of section 2(24)(iia) of the I.T.Act if the registration u/s 12A is not available to the assessee. - AT
Assessment of trust as AOP - exclusion of Corpus funds - all the voluntary contributions received by the assessee are taxable within the meaning of section 2(24)(iia) of the I.T.Act if the registration u/s 12A is not available to the assessee. - AT
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