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...
TP adjustment - scope of TP adjustment when assessee is eligible for exemption u/s 10B - Irrespective of profit making ability and exemption available in the country of operation the transfer price of the global market and the corporates must be within the band of pricing - tax saving alone cannot be a decision making process to restrict any TP adjustment
TP adjustment - scope of TP adjustment when assessee is eligible for exemption u/s 10B - Irrespective of profit making ability and exemption available in the country of operation the transfer price of the global market and the corporates must be within the band of pricing - tax saving alone cannot be a decision making process to restrict any TP adjustment
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