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 towards commission expenditure - The payments in commission are made on a monthly/periodical basis based on the clearing of the bills of the assessee pursuant to periodical invoices raised by those commission agents - payments are made by a/c payee cheques - no iota of evidence to suspect the genuineness of these transactions - No additions.
Disallowance towards commission expenditure - The payments in commission are made on a monthly/periodical basis based on the clearing of the bills of the assessee pursuant to periodical invoices raised by those commission agents - payments are made by a/c payee cheques - no iota of evidence to suspect the genuineness of these transactions - No additions.
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