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...
Allowability of interest on borrowed funds - loan taken for acquisition of share - assessee acquired shares of DPSC Ltd which is in the similar business to control stake is a commencement of business - allowable as deduction u/s 36(1)(iii) as it is a commercial expediency with a view to expand business and acquiring, controlling interest in subsidiary companies
Allowability of interest on borrowed funds - loan taken for acquisition of share - assessee acquired shares of DPSC Ltd which is in the similar business to control stake is a commencement of business - allowable as deduction u/s 36(1)(iii) as it is a commercial expediency with a view to expand business and acquiring, controlling interest in subsidiary companies
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