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...
Invoking provisions of section 40A(3) - cash payment - As it is the requirement of these agents to make the payment in cash for goods, i.e. milk, to the cattle owners, who belong to economically weaker section, on behalf of the assessee the impugned payments are squarely covered by the exceptions provided in clause (l) of Rule 6DD - AT
Invoking provisions of section 40A(3) - cash payment - As it is the requirement of these agents to make the payment in cash for goods, i.e. milk, to the cattle owners, who belong to economically weaker section, on behalf of the assessee the impugned payments are squarely covered by the exceptions provided in clause (l) of Rule 6DD - AT
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