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 made on account of difference in credit of income as per 26AS statement and income credited in Income and Expenditure accounts - these timing differences in recognition of revenue with corresponding TDS, will get adjusted in future years and hence there is no tax evasion on the part of the assessee.
Addition made on account of difference in credit of income as per 26AS statement and income credited in Income and Expenditure accounts - these timing differences in recognition of revenue with corresponding TDS, will get adjusted in future years and hence there is no tax evasion on the part of the assessee.
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