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...
Accrual of income - addition on account of accrued interest on NPA account as income - the assessee had adequately established that the interest received during the year as pertained to interest of those years when the assessee was accounting for the interest on accrual basis - No additions - AT
Accrual of income - addition on account of accrued interest on NPA account as income - the assessee had adequately established that the interest received during the year as pertained to interest of those years when the assessee was accounting for the interest on accrual basis - No additions - AT
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