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...
Computation of MAT - Addition on debenture redemption reserve fund - adjustments to book profit u/s. 115JA/ 115JB - the amount set aside to redeem debentures must be treated as a known liability and cannot be considered to be a reserve - cannot an treated as unascertained liability.
Computation of MAT - Addition on debenture redemption reserve fund - adjustments to book profit u/s. 115JA/ 115JB - the amount set aside to redeem debentures must be treated as a known liability and cannot be considered to be a reserve - cannot an treated as unascertained liability.
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