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...
Exemption u/s 11 - The claim of assessee for accumulation ought to have been accepted by the revenue authorities. Even in the order of assessment the AO has accepted that Form-10 was filed by the assessee and the only grievance was that the purpose for accumulation was not mentioned. - No additions.
Exemption u/s 11 - The claim of assessee for accumulation ought to have been accepted by the revenue authorities. Even in the order of assessment the AO has accepted that Form-10 was filed by the assessee and the only grievance was that the purpose for accumulation was not mentioned. - No additions.
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