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...
Accrual of income - interest income earned on the fixed deposit - effect of overriding title - the Assessee never becomes the owner of money and as such the addition made by the AO was not sustainable in both the assessment years. - HC
Accrual of income - interest income earned on the fixed deposit - effect of overriding title - the Assessee never becomes the owner of money and as such the addition made by the AO was not sustainable in both the assessment years. - HC
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