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...
Loss due to fraud and embezzlement - The loss that has been occurred to the assessee because of those factors which are very much irrecoverable and in the practical context, these have to be allowed since it has been incurred by the assessee for facilitating the carrying on of the business of the assessee. - AT
Loss due to fraud and embezzlement - The loss that has been occurred to the assessee because of those factors which are very much irrecoverable and in the practical context, these have to be allowed since it has been incurred by the assessee for facilitating the carrying on of the business of the assessee. - AT
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