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...
Depreciation on intellectual property rights (IPR) acquired and purchased by the assessee - There cannot be a ground and reason to hold that the assessee had not “put to use” the intellectual property rights assets in the year in question.
Depreciation on intellectual property rights (IPR) acquired and purchased by the assessee - There cannot be a ground and reason to hold that the assessee had not “put to use” the intellectual property rights assets in the year in question.
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