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...
Undisclosed purchase - purchases were not properly entered - there was “Excess Book Stock” as compared to “Physical Stock - We do not find any perversity in the said findings of the learned Tribunal based on the admission of the Assessee himself
Undisclosed purchase - purchases were not properly entered - there was “Excess Book Stock” as compared to “Physical Stock - We do not find any perversity in the said findings of the learned Tribunal based on the admission of the Assessee himself
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