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...
Disallowance u/s 80IB - There is no bar or prohibition in section 80IB on sale (slumpsale) of eligible undertaking to another assessee and the benefit attached with eligible undertaking cannot be denied to another assessee - mere change of ownership would not affect the claim of deductions. - AT
Disallowance u/s 80IB - There is no bar or prohibition in section 80IB on sale (slumpsale) of eligible undertaking to another assessee and the benefit attached with eligible undertaking cannot be denied to another assessee - mere change of ownership would not affect the claim of deductions. - AT
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