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...
Revenue recognition - Applicability of AS-9 - Accrual basis of accounting - The argument based on accountancy practice has little merit if such practice cannot be justified by any provision of the Statute or is contrary to it - AT
Revenue recognition - Applicability of AS-9 - Accrual basis of accounting - The argument based on accountancy practice has little merit if such practice cannot be justified by any provision of the Statute or is contrary to it - AT
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