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 provision made in respect of an anticipated loss being the diminution in the value of Govt. of India Fertilizer Bonds - the methodology adopted by the assessee was a scientific method. It was supported by the rates issued by the Govt. of India itself and the loss was actually determinable, though would be actually incurred at the time of redemption. - AT
Disallowance of provision made in respect of an anticipated loss being the diminution in the value of Govt. of India Fertilizer Bonds - the methodology adopted by the assessee was a scientific method. It was supported by the rates issued by the Govt. of India itself and the loss was actually determinable, though would be actually incurred at the time of redemption. - AT
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