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 u/s 40A(3) - cash payment for freight charges paid to clearing and forwarding against for clearing our goods for exports - disallowances u/s 40A(3), cannot be made if the genuineness of the transaction has not been doubted by the authorities below
Addition u/s 40A(3) - cash payment for freight charges paid to clearing and forwarding against for clearing our goods for exports - disallowances u/s 40A(3), cannot be made if the genuineness of the transaction has not been doubted by the authorities below
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