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 of deposits found in bank statement u/s 68 - cash flow statement - adequate cash flow was available for deposits in the bank account. Hence, the assessee deserves to succeed on this count that there was available cash withdrawal from earlier period which is sufficient to cover the deposit amount. - AT
Addition of deposits found in bank statement u/s 68 - cash flow statement - adequate cash flow was available for deposits in the bank account. Hence, the assessee deserves to succeed on this count that there was available cash withdrawal from earlier period which is sufficient to cover the deposit amount. - AT
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