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...
Deduction u/s 10A and alternative claim u/s 80IB(8A) - export of computer software - assessee contended to be STP involved in software development - denial of deduction on ground that assessee’s operations do not have computer as primary and predominant hardware tool and scientific methods/tool are used - AT
Deduction u/s 10A and alternative claim u/s 80IB(8A) - export of computer software - assessee contended to be STP involved in software development - denial of deduction on ground that assessee’s operations do not have computer as primary and predominant hardware tool and scientific methods/tool are used - AT
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