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 56(2)(vii)(b) - receipt of property through general power of attorney without consideration - it cannot be said that the assessee received the property as owner and was liable to pay the tax on the stamp duty value of the said property
Addition u/s 56(2)(vii)(b) - receipt of property through general power of attorney without consideration - it cannot be said that the assessee received the property as owner and was liable to pay the tax on the stamp duty value of the said property
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