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...
Computation of ‘Cost of Sales’ and closing value of land - matching concept for determination of true profits - where the sale revenue has been recognized on the basis of FSI sold, the costs of FSI also needs to be determined on the same principles - The determination of ‘Cost of Sales’ in terms of geographical area would give totally distorted picture - not permitted
Computation of ‘Cost of Sales’ and closing value of land - matching concept for determination of true profits - where the sale revenue has been recognized on the basis of FSI sold, the costs of FSI also needs to be determined on the same principles - The determination of ‘Cost of Sales’ in terms of geographical area would give totally distorted picture - not permitted
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