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...
Disallowance of ESIC and EPF u/s 37(1) - assessee was not under obligation to discharge the liability under EPF and ESIC in respect of employees of sub-contractors - the assessee as part of good corporate governance complied with the provisions of beneficial legislature qua the contract labourers who were working for the assessee - wholly and exclusively for the purpose of business - duly allowable
Disallowance of ESIC and EPF u/s 37(1) - assessee was not under obligation to discharge the liability under EPF and ESIC in respect of employees of sub-contractors - the assessee as part of good corporate governance complied with the provisions of beneficial legislature qua the contract labourers who were working for the assessee - wholly and exclusively for the purpose of business - duly allowable
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