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...
Taxation of retention money not accrued during the year - Accrual of income - as per AO addition has been rightly made during the course of assessment as well as in section 115JB MAT computation - The Revenue fails to rebut the clinching fact that there is no surety about the impugned retention money to be finally refunded to the taxpayer - Additions deleted.
Taxation of retention money not accrued during the year - Accrual of income - as per AO addition has been rightly made during the course of assessment as well as in section 115JB MAT computation - The Revenue fails to rebut the clinching fact that there is no surety about the impugned retention money to be finally refunded to the taxpayer - Additions deleted.
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