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...
Restriction of MAT credit - whether for the purposes of computing the MAT credit u/s 115JAA whether tax include surcharge and education cess or not? - Held Yes
Restriction of MAT credit - whether for the purposes of computing the MAT credit u/s 115JAA whether tax include surcharge and education cess or not? - Held Yes
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