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...
Exemption u/s 54B - agriculture land or not - land was just adjacent to the sea - To carry agricultural operation water is very much required and sea water is not useful for carrying any agricultural activities or to raise any agricultural crop - we are of the considered opinion that the assessee has not carried any agricultural activities - AT
Exemption u/s 54B - agriculture land or not - land was just adjacent to the sea - To carry agricultural operation water is very much required and sea water is not useful for carrying any agricultural activities or to raise any agricultural crop - we are of the considered opinion that the assessee has not carried any agricultural activities - AT
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