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...
Reopening of assessment - addition in respect of receipt of share capital money as accommodation entry, the doubts of the A.O. have not been cleared by the assessee at any stage. The burden is upon assessee to prove the ingredients of Section 68
Reopening of assessment - addition in respect of receipt of share capital money as accommodation entry, the doubts of the A.O. have not been cleared by the assessee at any stage. The burden is upon assessee to prove the ingredients of Section 68
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