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...
Application for approval u/s 10(23C)(vi) rejected - assessee is already granted registration u/s 12AA - registration u/s 12AA of the Act granted to the assessee should not be a bar for granting approval u/s 10(23C)(vii) - CIT(E) directed to decide the matter afresh - AT
Application for approval u/s 10(23C)(vi) rejected - assessee is already granted registration u/s 12AA - registration u/s 12AA of the Act granted to the assessee should not be a bar for granting approval u/s 10(23C)(vii) - CIT(E) directed to decide the matter afresh - AT
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