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...
Concessional rate of tax - rejection of 'C' Forms - there is no proof regarding verification made or materials collected - Unless and until the Assessing Authority became convinced that the 'C' Forms produced were not genuine, based on any materials collected, the assessments made rejecting the claim for concessional rate of tax, cannot be sustained.
Concessional rate of tax - rejection of 'C' Forms - there is no proof regarding verification made or materials collected - Unless and until the Assessing Authority became convinced that the 'C' Forms produced were not genuine, based on any materials collected, the assessments made rejecting the claim for concessional rate of tax, cannot be sustained.
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