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...
Benami transactions - The existence of the “benami” transaction has to be proved by the authorities i.e. the person who alleges the transaction - The transaction where cash is paid to person in lieu of a future promise cannot be a “benami” transaction as there is no lending of name.
Benami transactions - The existence of the “benami” transaction has to be proved by the authorities i.e. the person who alleges the transaction - The transaction where cash is paid to person in lieu of a future promise cannot be a “benami” transaction as there is no lending of name.
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