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...
Disallowance u/s 40A(3) – Rule 6DD – Staggered the payment - It is very clear that the assessee consciously split up the payments in whole of the year, which is impracticable, illogical - AT
Disallowance u/s 40A(3) – Rule 6DD – Staggered the payment - It is very clear that the assessee consciously split up the payments in whole of the year, which is impracticable, illogical - AT
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