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...
Deemed income u/s 69B - notional interest as income on loan/advances to sister concern - Since there is no specific provision in the Income Tax Act for bringing to tax notional interest as income on loan/advances to sister concern, no additions can be made.
Deemed income u/s 69B - notional interest as income on loan/advances to sister concern - Since there is no specific provision in the Income Tax Act for bringing to tax notional interest as income on loan/advances to sister concern, no additions can be made.
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