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...
Additions u/s 68 - deposit of cash out of cash withdrawn by appellant from the same bank account for purchase of immoveable property - Due regard and latitude to human conduct and behaviour has to be given and accepted - no additions - HC
Additions u/s 68 - deposit of cash out of cash withdrawn by appellant from the same bank account for purchase of immoveable property - Due regard and latitude to human conduct and behaviour has to be given and accepted - no additions - HC
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