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 loss of trading in bonds - The A.O. has not contradicted the claim of the assessee that there was no prohibition on carrying out off market transactions - No justification to disallow the loss on transactions on lands merely on doubt assumption basis.
Disallowance of loss of trading in bonds - The A.O. has not contradicted the claim of the assessee that there was no prohibition on carrying out off market transactions - No justification to disallow the loss on transactions on lands merely on doubt assumption basis.
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