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...
Claim of expenditure - proof of commencement of business activity - earning of income during the year is not a prerequisite for coming to the conclusion that business is in fact carried on during the year
Claim of expenditure - proof of commencement of business activity - earning of income during the year is not a prerequisite for coming to the conclusion that business is in fact carried on during the year
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