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 u/s 68 - bogus LTCG - off market purchase in physical form by paying cash - The assessee has failed to furnish the proof of source for the purchase transactions - LTCG claimed exempt u/s. 10(38)is disallowed and sales proceeds on sale of shares added u/s 68
Addition u/s 68 - bogus LTCG - off market purchase in physical form by paying cash - The assessee has failed to furnish the proof of source for the purchase transactions - LTCG claimed exempt u/s. 10(38)is disallowed and sales proceeds on sale of shares added u/s 68
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