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...
Fictitious loss by way of Client Code Modification (CCM) - unexplained expenditure - The transactions of were duly supported by bills/contract notes and also confirm by parties whose name appear in the data that the transactions are belonging to them only and there is nothing on record establishes any collusion/connivance of the assessee with the share broker - losses allowable
Fictitious loss by way of Client Code Modification (CCM) - unexplained expenditure - The transactions of were duly supported by bills/contract notes and also confirm by parties whose name appear in the data that the transactions are belonging to them only and there is nothing on record establishes any collusion/connivance of the assessee with the share broker - losses allowable
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