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...
Addition u/s 69C - expenditure stated as “MLA Balance” - illegal amount to be paid - It is submitted that, the amounts do not reflect payments already made. There are only payable at the time of seized of the papers. - Additions confirmed.
Addition u/s 69C - expenditure stated as “MLA Balance” - illegal amount to be paid - It is submitted that, the amounts do not reflect payments already made. There are only payable at the time of seized of the papers. - Additions confirmed.
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