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...
Deduction u/s 80IC - higher rate of profit declared by the assessee-company in its Dehradun Unit is justifiable as cost of production of the same Unit was lower due to various incentives and the availability of raw material at cheaper rates in the local market
Deduction u/s 80IC - higher rate of profit declared by the assessee-company in its Dehradun Unit is justifiable as cost of production of the same Unit was lower due to various incentives and the availability of raw material at cheaper rates in the local market
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