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...
Revision u/s 263 - Disallowance of genuineness of salary and other expenses - payment of huge salary in cash - AO passed the order without proper verification is concerned - matter needs to be remitted to the AO only on question of verification of salary, rent and wages and freight expenses incurred by assessee for verification - Order of ITAT modified.
Revision u/s 263 - Disallowance of genuineness of salary and other expenses - payment of huge salary in cash - AO passed the order without proper verification is concerned - matter needs to be remitted to the AO only on question of verification of salary, rent and wages and freight expenses incurred by assessee for verification - Order of ITAT modified.
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