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 towards interest on capital - the interest payment relating to the addition confirmed as unexplained cash credit in the hands of the firm is not allowable and the same is to be treated as income in the hands of the firm as unexplained sources. - AT
Additions towards interest on capital - the interest payment relating to the addition confirmed as unexplained cash credit in the hands of the firm is not allowable and the same is to be treated as income in the hands of the firm as unexplained sources. - AT
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