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...
Denial of claim of deduction u/s 80IB - the “industrial undertaking” should not be formed by “splitting up” or “re-construction” of a business already in existence - AT
Denial of claim of deduction u/s 80IB - the “industrial undertaking” should not be formed by “splitting up” or “re-construction” of a business already in existence - AT
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