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 on account of expenses incurred through sub-contractors - bogus expenditure - these companies are merely paper companies, having complied with proper paper work, but not possessing necessary expertise to render technical services to the assessee - Even if TDS was deducted, expenditure cannot be allowed. - AT
Disallowance on account of expenses incurred through sub-contractors - bogus expenditure - these companies are merely paper companies, having complied with proper paper work, but not possessing necessary expertise to render technical services to the assessee - Even if TDS was deducted, expenditure cannot be allowed. - AT
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