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 being expense for valuation certification u/s 37(1) - Professional fee paid for share valuation certificate - the expenses claimed by the assessee have been incurred during the regular course of business and cannot be treated as capital expenses. - AT
Addition being expense for valuation certification u/s 37(1) - Professional fee paid for share valuation certificate - the expenses claimed by the assessee have been incurred during the regular course of business and cannot be treated as capital expenses. - AT
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