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...
Unaccounted cash - On-money received - Merely finding the name of the transaction in the excel sheet during the search cannot held the assessee responsible for cash which was never tracked down by the Assessing Officer from assessee’s books of accounts. - AT
Unaccounted cash - On-money received - Merely finding the name of the transaction in the excel sheet during the search cannot held the assessee responsible for cash which was never tracked down by the Assessing Officer from assessee’s books of accounts. - AT
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