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...
Merely because an income was offered by another person in its return of income will not exonerate the assessee from inclusion of such income in its return which was earned and received by it - AT
Merely because an income was offered by another person in its return of income will not exonerate the assessee from inclusion of such income in its return which was earned and received by it - AT
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