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 replacement of dies and moulds as current repairs - when the dies and moulds were attached to the machine to manufacture the designed product, the claim would fall for consideration only u/s 31 as revenue expenses
Allowability of replacement of dies and moulds as current repairs - when the dies and moulds were attached to the machine to manufacture the designed product, the claim would fall for consideration only u/s 31 as revenue expenses
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