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...
Long term capital gain - reliance on unsigned computerized Satakhat (agreement for sale) found during course of survey in premiss of third party lawyer - There was no corroborative and supporting evidence to support the alleged incriminating material - In absence of corroborative and supporting evidence, no justification for making addition on account of long term capital gains. - AT
Long term capital gain - reliance on unsigned computerized Satakhat (agreement for sale) found during course of survey in premiss of third party lawyer - There was no corroborative and supporting evidence to support the alleged incriminating material - In absence of corroborative and supporting evidence, no justification for making addition on account of long term capital gains. - AT
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