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...
The assessee was not a resident in India in terms of section 6 and was therefore, neither required to file any return of income in India not any income can be brought to tax in India. Therefore, the deposits made in the foreign bank account cannot be held to be included as taxable income in India. - AT
The assessee was not a resident in India in terms of section 6 and was therefore, neither required to file any return of income in India not any income can be brought to tax in India. Therefore, the deposits made in the foreign bank account cannot be held to be included as taxable income in India. - AT
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