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...
Setoff of short term loss from shares with short term capital gain - Genuineness of loss - the AO could not have on one hand accepted the genuineness of the transaction which resulted in gain, but on other hand doubted the genuineness only where the transaction resulted in loss.
Setoff of short term loss from shares with short term capital gain - Genuineness of loss - the AO could not have on one hand accepted the genuineness of the transaction which resulted in gain, but on other hand doubted the genuineness only where the transaction resulted in loss.
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