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...
Partially rejection of books - assessee incurred the expenses for it’s two activities hence AO cannot reject books partially and if the books of the accounts are rejected then the income from both the sources needs to be estimated and no separate addition for commission payment or u/s 41(1) is called for
Partially rejection of books - assessee incurred the expenses for it’s two activities hence AO cannot reject books partially and if the books of the accounts are rejected then the income from both the sources needs to be estimated and no separate addition for commission payment or u/s 41(1) is called for
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