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...
Disallowance of front end fees - front end fee is part of interest under Section 2(28A)- interest payment was spread over the duration of the loan - Therefore, it should spread over a period of time
Disallowance of front end fees - front end fee is part of interest under Section 2(28A)- interest payment was spread over the duration of the loan - Therefore, it should spread over a period of time
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