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...
Exemption u/s 11 - the cash (capitation fees) which has been collected by the assessee has not been recorded in the books of the assessee but has been kept outside the regular books - during search cash was not found either of the premises of the assessee or in the hands of the Managing Trustees - deemed to be used in violation of Sec. 13(1)(c)
Exemption u/s 11 - the cash (capitation fees) which has been collected by the assessee has not been recorded in the books of the assessee but has been kept outside the regular books - during search cash was not found either of the premises of the assessee or in the hands of the Managing Trustees - deemed to be used in violation of Sec. 13(1)(c)
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