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...
Disallowance of expenses u/s 37(1)and depreciation u/s 32 - commencement of business - it can be said that the business had been set up and that the only thing was that the assessee was not able to generate any income out of the same - the business would commence when the activity which is first in point of time and which must necessarily precede all other activities, is started - expenses/depreciation is allowable
Disallowance of expenses u/s 37(1)and depreciation u/s 32 - commencement of business - it can be said that the business had been set up and that the only thing was that the assessee was not able to generate any income out of the same - the business would commence when the activity which is first in point of time and which must necessarily precede all other activities, is started - expenses/depreciation is allowable
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