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...
Disallowance of payment made to relatives of the Directors u/s 40A(2)(b) - AO should have considered experience, qualification and technical competency, which has not been done in the instant case - Director is taxable at maximum marginal rate - Additions deleted.
Disallowance of payment made to relatives of the Directors u/s 40A(2)(b) - AO should have considered experience, qualification and technical competency, which has not been done in the instant case - Director is taxable at maximum marginal rate - Additions deleted.
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