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 towards non-existing profits - Tribunal has included the value of goods, loading and unloading charges, railway freight as also the service charges received in turnover - Once the modus operandi of the assessee's business has been accepted and held that Societies were running for the benefit for their members and service charges had been included in the taxable turnover - no addition on presumptive basis permissible
Addition towards non-existing profits - Tribunal has included the value of goods, loading and unloading charges, railway freight as also the service charges received in turnover - Once the modus operandi of the assessee's business has been accepted and held that Societies were running for the benefit for their members and service charges had been included in the taxable turnover - no addition on presumptive basis permissible
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