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...
Trasfer pricing - CIT(A) granted the benefit of ±5% without any standard deduction - In view of legislative amendment carried out retrospectively, the assessee cannot claim any standard deduction.
Trasfer pricing - CIT(A) granted the benefit of ±5% without any standard deduction - In view of legislative amendment carried out retrospectively, the assessee cannot claim any standard deduction.
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