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...
Admissibility of expenditures incurred by the assessee (a pharmaceutical company) u/s 37 - disallowance of referral fees paid to doctors in violation of public policy and regulations formulated by the Medical Council of India ("MC!') - We uphold the lower authorities action treating the assessee's referral fees as commission payment not allowable in principle. - AT
Admissibility of expenditures incurred by the assessee (a pharmaceutical company) u/s 37 - disallowance of referral fees paid to doctors in violation of public policy and regulations formulated by the Medical Council of India ("MC!') - We uphold the lower authorities action treating the assessee's referral fees as commission payment not allowable in principle. - AT
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