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...
Computation of LTCG - applicability of Section 50C - property under sale was under various encumbrances and the assessee was not having the absolute marketable title of the said property - adoption of stamp valuation as a sale consideration u/s 50C was not justified
Computation of LTCG - applicability of Section 50C - property under sale was under various encumbrances and the assessee was not having the absolute marketable title of the said property - adoption of stamp valuation as a sale consideration u/s 50C was not justified
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