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...
Exemption u/s 11 - Accumulation of income - whether 15% accumulation for application in future has to be calculated on gross receipt or net receipt after deduction of revenue expenditure - accumulation u/s. 11(1)(a) should be allowed as claimed by the assessee
Exemption u/s 11 - Accumulation of income - whether 15% accumulation for application in future has to be calculated on gross receipt or net receipt after deduction of revenue expenditure - accumulation u/s. 11(1)(a) should be allowed as claimed by the assessee
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