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...
Addition u/s 40A(3) - cash payments made by the assessee to the agriculturists/farmers for purchase of land - CIT-A have found that the assessee has failed to prove the stand taken by him that the transaction took place at the place where there were no banking facilities. The aforesaid finding has been affirmed by Tribunal. - Additions confirmed - HC
Addition u/s 40A(3) - cash payments made by the assessee to the agriculturists/farmers for purchase of land - CIT-A have found that the assessee has failed to prove the stand taken by him that the transaction took place at the place where there were no banking facilities. The aforesaid finding has been affirmed by Tribunal. - Additions confirmed - HC
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