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...
Unexplained Cash Credit – temporary loan from friends and relatives abroad for the purpose of filing immigration application for L1 visa for USA - Assessee had established the necessary ingredients - No addition - HC
Unexplained Cash Credit – temporary loan from friends and relatives abroad for the purpose of filing immigration application for L1 visa for USA - Assessee had established the necessary ingredients - No addition - HC
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