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...
Receipt of amount without consideration - income from other sources u/s 56(2)(vi) - Amount received from employer’s various employee’s welfare trusts - when the income of all the aforesaid 12 discretionary trusts have been charged to tax, the same income cannot be taxed twice when fell into the hands of the assessee - AT
Receipt of amount without consideration - income from other sources u/s 56(2)(vi) - Amount received from employer’s various employee’s welfare trusts - when the income of all the aforesaid 12 discretionary trusts have been charged to tax, the same income cannot be taxed twice when fell into the hands of the assessee - AT
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