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...
Additions against Excess stock found - the value of surplus stock in the facts and circumstances of the assessee’s case did not represent assessee’s unexplained investment u/s 69 and it constituted its regular business income for the year under consideration. - AT
Additions against Excess stock found - the value of surplus stock in the facts and circumstances of the assessee’s case did not represent assessee’s unexplained investment u/s 69 and it constituted its regular business income for the year under consideration. - AT
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