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...
Nature of expenditure - manufacturing and administrative expenses incurred by the appellant for development of a product in the course of its manufacturing activity which was already carried on - Same cannot be treated as revenue expenditure. - HC
Nature of expenditure - manufacturing and administrative expenses incurred by the appellant for development of a product in the course of its manufacturing activity which was already carried on - Same cannot be treated as revenue expenditure. - HC
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