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...
Claim of exemption u/s 11 denied - medical facilities for poor patients - beds reserved for needy and poor persons kept - The test cannot be percentage of the poor patients actually treated, in the absence of any evidence to indicate that poor patients were denied in-house treatment in the hospital. - HC
Claim of exemption u/s 11 denied - medical facilities for poor patients - beds reserved for needy and poor persons kept - The test cannot be percentage of the poor patients actually treated, in the absence of any evidence to indicate that poor patients were denied in-house treatment in the hospital. - HC
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