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...
Claim of deduction u/s. 80IA - Condition to employ more than ten persons - Just because such persons, were not regular employees of the assessee, would not mean that they were not employed by the assessee for the purpose of new production project.
Claim of deduction u/s. 80IA - Condition to employ more than ten persons - Just because such persons, were not regular employees of the assessee, would not mean that they were not employed by the assessee for the purpose of new production project.
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