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...
Nature of expenditure - current repairs - cost of replacement of machineries like Motor Rollers, Spindles, Gears etc. in the Textile Mill - the replacement of the machineries as a whole by the Assessee cannot be held to be current repairs or allowable revenue expenditure
Nature of expenditure - current repairs - cost of replacement of machineries like Motor Rollers, Spindles, Gears etc. in the Textile Mill - the replacement of the machineries as a whole by the Assessee cannot be held to be current repairs or allowable revenue expenditure
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