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 u/s 148 - Unexplained cash credit u/s 68 - AO has not mentioned whether the amount is on account of share capital or loans or expenses. - Addition has been made without specifying as to the nature of the amounts and also without examining the credits in the books of the assessee - Additions deleted.
Reopening u/s 148 - Unexplained cash credit u/s 68 - AO has not mentioned whether the amount is on account of share capital or loans or expenses. - Addition has been made without specifying as to the nature of the amounts and also without examining the credits in the books of the assessee - Additions deleted.
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