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 professional charges - Except for placing on record the bifurcated details of professional charges incurred during the year under consideration, we find that, the assessee had failed to place on record any such material which would substantiate its claim of having incurred the so called professional charges wholly and exclusively for the purpose of its business. - Additions confirmed - AT
Disallowance of professional charges - Except for placing on record the bifurcated details of professional charges incurred during the year under consideration, we find that, the assessee had failed to place on record any such material which would substantiate its claim of having incurred the so called professional charges wholly and exclusively for the purpose of its business. - Additions confirmed - AT
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