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 entitled for deduction on account of interest paid to Allahabad Bank on the borrowed funds under section 57(iii) - such interest payment being more than the interest earned in both the years under consideration, no addition was liable to be made to the total income of the assessee on this issue - AT
The assessee was entitled for deduction on account of interest paid to Allahabad Bank on the borrowed funds under section 57(iii) - such interest payment being more than the interest earned in both the years under consideration, no addition was liable to be made to the total income of the assessee on this issue - AT
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