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...
Deduction u/s 80IA - AO directed to compute the profits u/s 80IA(5) if such eligible business is the only sources of income and only the losses of the years beginning from the initial AY are to be brought forward and not losses of earlier years which have been already set off against the income - AT
Deduction u/s 80IA - AO directed to compute the profits u/s 80IA(5) if such eligible business is the only sources of income and only the losses of the years beginning from the initial AY are to be brought forward and not losses of earlier years which have been already set off against the income - AT
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