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...
Addition u/s 40A(3) - payments of expenditure in cash exceeding permeable limits - payments were made in cash for the business expediency of the assessee and as per requirement specified by BSNL. - even if the assessee does not fall in any of the clause of Rule 6DD, invoking the provisions of section 40A(3) can be dispensed with. - AT
Addition u/s 40A(3) - payments of expenditure in cash exceeding permeable limits - payments were made in cash for the business expediency of the assessee and as per requirement specified by BSNL. - even if the assessee does not fall in any of the clause of Rule 6DD, invoking the provisions of section 40A(3) can be dispensed with. - AT
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