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...
Treatment of cash seized during the search as advance tax - Explanation was brought by the Finance Act 2013 with effect from 1st June 2013. Thus the same cannot be applied to the facts of the case on hand. - AO directed to treat the seized cash as an advance tax with effect from the date of seizure of cash. - AT
Treatment of cash seized during the search as advance tax - Explanation was brought by the Finance Act 2013 with effect from 1st June 2013. Thus the same cannot be applied to the facts of the case on hand. - AO directed to treat the seized cash as an advance tax with effect from the date of seizure of cash. - AT
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