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...
Undisclosed investment in stock and property - when the assessee himself had disclosed higher stock, question of taking a view that assessee had suppressed sales for making investment towards purchase of goods which is reflected in the higher stock figures does not appear to be reasonable. - HC
Undisclosed investment in stock and property - when the assessee himself had disclosed higher stock, question of taking a view that assessee had suppressed sales for making investment towards purchase of goods which is reflected in the higher stock figures does not appear to be reasonable. - HC
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