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 for cash component of interest - Reliance on statement of the assessee during survey proceedings - There is no other evidence on record except the statement of the assessee recorded during survey proceedings, which has already been retracted by the assessee. - Additions deleted - AT
Addition for cash component of interest - Reliance on statement of the assessee during survey proceedings - There is no other evidence on record except the statement of the assessee recorded during survey proceedings, which has already been retracted by the assessee. - Additions deleted - AT
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