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...
Cessation of liability u/s 41(1) - conversion of the loan as well as the unpaid interest into share capital - when there was no writing off of liabilities and only the sub-head, under which, the liability was shown in the account books of the assessee was changed and it continued to remain liable to pay even after change of entries, there could be no cessation of liability - not taxable
Cessation of liability u/s 41(1) - conversion of the loan as well as the unpaid interest into share capital - when there was no writing off of liabilities and only the sub-head, under which, the liability was shown in the account books of the assessee was changed and it continued to remain liable to pay even after change of entries, there could be no cessation of liability - not taxable
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