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...
Addition u/s 69C on the basis of valuation report - unexplained expenditure - assessee has not maintained books of account and fail to furnish bills and vouchers in support of material purchased to substantiate the cost of construction of the house - additions confirmed.
Addition u/s 69C on the basis of valuation report - unexplained expenditure - assessee has not maintained books of account and fail to furnish bills and vouchers in support of material purchased to substantiate the cost of construction of the house - additions confirmed.
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