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...
Payment of bonus to shareholder employees / directors - allowability u/s 36(1)(ii) - the payment made to the four employee directors of the company is not a payment made in lieu of dividend as in fact found on facts by the Tribunal. - No additions.
Payment of bonus to shareholder employees / directors - allowability u/s 36(1)(ii) - the payment made to the four employee directors of the company is not a payment made in lieu of dividend as in fact found on facts by the Tribunal. - No additions.
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