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 interest income relying on 26AS - assessee claimed that interest income did not pertain to it and company has not even claimed the credit of TDS - onus will be on the AO to bring on record independent evidence after making enquiries from the payees - assessee cannot be expected to discharge the impossible burden of proving a negative
Addition of interest income relying on 26AS - assessee claimed that interest income did not pertain to it and company has not even claimed the credit of TDS - onus will be on the AO to bring on record independent evidence after making enquiries from the payees - assessee cannot be expected to discharge the impossible burden of proving a negative
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