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...
Source of income with regard to storage charges was not business of assessee, but was failure of buyer to receive delivery of goods in compliance with terms of contract - deduction u/s 80IB not allowed - AT
Source of income with regard to storage charges was not business of assessee, but was failure of buyer to receive delivery of goods in compliance with terms of contract - deduction u/s 80IB not allowed - AT
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