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...
Sale of asset - adventure in the nature of trade or would be the normal sale of assets attracting long term capital gain - Revenue’s stand is that pursuit of higher profit by itself would confer on the transaction the character of business venture. - HC
Sale of asset - adventure in the nature of trade or would be the normal sale of assets attracting long term capital gain - Revenue’s stand is that pursuit of higher profit by itself would confer on the transaction the character of business venture. - HC
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