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...
Addition u/s 68 on account of claim of gifts - mere claim of gift would not fall in the ambit of provisions of section 56(2)(vii) - when the assessee has failed to establish the claim of gift then the said amount has to be added as unexplained cash credit under section 68.
Addition u/s 68 on account of claim of gifts - mere claim of gift would not fall in the ambit of provisions of section 56(2)(vii) - when the assessee has failed to establish the claim of gift then the said amount has to be added as unexplained cash credit under section 68.
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