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...
Capital gain computation - cost of acquisition - assessee was not confronted by the AO before estimating the cost of acquisition of land as on 01.04.1981 without any basis - keeping aside rather ignoring the report of the registered valuer without any discussion is unjustified
Capital gain computation - cost of acquisition - assessee was not confronted by the AO before estimating the cost of acquisition of land as on 01.04.1981 without any basis - keeping aside rather ignoring the report of the registered valuer without any discussion is unjustified
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