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...
Disallowance u/s.40A(3) - cash payment against purchase of old gold ornaments under auction - As per the assessee, identity of the person to whom he had made the payments were established and genuineness of the purchases were not doubted - assessee failed to pass the test - additions confirmed.
Disallowance u/s.40A(3) - cash payment against purchase of old gold ornaments under auction - As per the assessee, identity of the person to whom he had made the payments were established and genuineness of the purchases were not doubted - assessee failed to pass the test - additions confirmed.
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