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 deduction u/s 80IA - Section 80IA is the clear cut to get 30% of the income as profit derived by the Assessee from the eligible business - it does say, 30% of the profit from the eligible business or 30% of the total income, whichever is lower -no substantial question of law
Computation of deduction u/s 80IA - Section 80IA is the clear cut to get 30% of the income as profit derived by the Assessee from the eligible business - it does say, 30% of the profit from the eligible business or 30% of the total income, whichever is lower -no substantial question of law
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