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...
Unexplained credits u/s 68 - share application received - assessee did not submit the details of the mode of payment by these two persons and that neither their identity nor the creditworthiness nor the genuineness of the transactions is proved - additions confirmed - AT
Unexplained credits u/s 68 - share application received - assessee did not submit the details of the mode of payment by these two persons and that neither their identity nor the creditworthiness nor the genuineness of the transactions is proved - additions confirmed - AT
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