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...
Protective addition - Addition of undisclosed income (on money consideration received by the assessee) - no similar addition was made in the hands of partners in their individual accounts - assessee firm was merely a confirming party and no consideration was received by the assessee firm - ITAT has correctly deleted the additions.
Protective addition - Addition of undisclosed income (on money consideration received by the assessee) - no similar addition was made in the hands of partners in their individual accounts - assessee firm was merely a confirming party and no consideration was received by the assessee firm - ITAT has correctly deleted the additions.
Note: It is a system-generated summary and is for quick reference only.
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