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...
Carry forward and set off of losses - the status of the company was “closely held company”, i. e. , a company in which public is not substantially interested, when the change in shareholding took place. - Since there is a change in shareholding exceeding 49%, the assessee company is not entitled to set off brought forward losses u/s 79.
Carry forward and set off of losses - the status of the company was “closely held company”, i. e. , a company in which public is not substantially interested, when the change in shareholding took place. - Since there is a change in shareholding exceeding 49%, the assessee company is not entitled to set off brought forward losses u/s 79.
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