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 of unexplained cash credit u/s 68 - bank account can’t be loosely called as books of account u/s 68 - ITAT can’t covert the addition from section 68 to section 69A - lack of cross examination and violation of principle of natural justice results is total nullity of the entire addition.
Addition of unexplained cash credit u/s 68 - bank account can’t be loosely called as books of account u/s 68 - ITAT can’t covert the addition from section 68 to section 69A - lack of cross examination and violation of principle of natural justice results is total nullity of the entire addition.
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