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 of assessee’s claim of long term capital loss - as per AO purchase and sale of shares was nothing but a colourable device to generate loss to be set off against capital gain - additions confirmed.
Disallowance of assessee’s claim of long term capital loss - as per AO purchase and sale of shares was nothing but a colourable device to generate loss to be set off against capital gain - additions confirmed.
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