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...
Determination of income u/s 44 - Taxing the income arising on account of shareholders profits - where the assessee company was engaged only in life insurance business and was not carrying on any other business, surplus or deficit as per shareholders account is to be aggregated with surplus or deficit with policyholders account for the purpose of determining the Profit & Loss Account of an assessee engaged in life insurance business u/s 44 of the Act. - AT
Determination of income u/s 44 - Taxing the income arising on account of shareholders profits - where the assessee company was engaged only in life insurance business and was not carrying on any other business, surplus or deficit as per shareholders account is to be aggregated with surplus or deficit with policyholders account for the purpose of determining the Profit & Loss Account of an assessee engaged in life insurance business u/s 44 of the Act. - AT
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