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...
Accrual of income - Addition towards interest on bank fixed deposits on the basis of TDS statements 26AS - given that the transaction has been reflected in Form 26AS, the onus is on the assessee to demonstrate that such transaction doesn’t represent real income in its hands - additions confirmed.
Accrual of income - Addition towards interest on bank fixed deposits on the basis of TDS statements 26AS - given that the transaction has been reflected in Form 26AS, the onus is on the assessee to demonstrate that such transaction doesn’t represent real income in its hands - additions confirmed.
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