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...
Disallowance of interest - Valuation of inventory - There is no such provision in section 145A(A) to include interest cost in the value of inventory - Therefor disallowance confirmed by CIT-A assessee should have taken into consideration the interest attributable to bringing the inventory to its present location and condition in accordance with explanation to section 145A(A) is not correct - AT
Disallowance of interest - Valuation of inventory - There is no such provision in section 145A(A) to include interest cost in the value of inventory - Therefor disallowance confirmed by CIT-A assessee should have taken into consideration the interest attributable to bringing the inventory to its present location and condition in accordance with explanation to section 145A(A) is not correct - AT
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