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...
Sale of unaccounted finished goods - Chairman in a disclosure petition u/s 132(4) accepted shortage of raw material on account of cash sale of the raw material itself and offer for tax - neither any evidence of the production of Ferro Alloys nor any evidence of its sales have been brought on record by the A.O. - no addition
Sale of unaccounted finished goods - Chairman in a disclosure petition u/s 132(4) accepted shortage of raw material on account of cash sale of the raw material itself and offer for tax - neither any evidence of the production of Ferro Alloys nor any evidence of its sales have been brought on record by the A.O. - no addition
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