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(2)(b) - unbalanced payment to doctors - payment to specified persons - No finding by the AO about as to what constitutes fair market price of the services rendered by the promoter directors - Remuneration of doctors must depend on their market worth, and determination of such market worth is uninfluenced by what other professionals in their area of expertise earn - AT
Addition u/s 40A(2)(b) - unbalanced payment to doctors - payment to specified persons - No finding by the AO about as to what constitutes fair market price of the services rendered by the promoter directors - Remuneration of doctors must depend on their market worth, and determination of such market worth is uninfluenced by what other professionals in their area of expertise earn - AT
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