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 depreciation - revenue doubts existence of plant and machinery - assessee has neither able to substantiate by way of any agreements entered into by it, with parties to which plant and machinery has been released on hire purchase nor able to establish existence of plant and machinery by way of corroborative evidences - no depreciation
Disallowance of depreciation - revenue doubts existence of plant and machinery - assessee has neither able to substantiate by way of any agreements entered into by it, with parties to which plant and machinery has been released on hire purchase nor able to establish existence of plant and machinery by way of corroborative evidences - no depreciation
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