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...
Claim of expenditure towards premium paid on forward covers of foreign exchange rates - Section 43A is not applicable to the facts of the present case since it is not the case of the Revenue that the foreign exchange loan has been taken for purchasing any asset outside the country. - assessee is entitled to claim the amortization of premium paid on foreign exchange contracts - AT
Claim of expenditure towards premium paid on forward covers of foreign exchange rates - Section 43A is not applicable to the facts of the present case since it is not the case of the Revenue that the foreign exchange loan has been taken for purchasing any asset outside the country. - assessee is entitled to claim the amortization of premium paid on foreign exchange contracts - AT
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