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...
Capital loss - sale of shares to sister concern when the transaction for sale to an outside buyer for a much higher price is being processed - the transaction is neither fraudulent nor a colourable device - Authorities cannot enter into the shoe of the assessee to decide the prudence of commercial expediency of a particular transaction.
Capital loss - sale of shares to sister concern when the transaction for sale to an outside buyer for a much higher price is being processed - the transaction is neither fraudulent nor a colourable device - Authorities cannot enter into the shoe of the assessee to decide the prudence of commercial expediency of a particular transaction.
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