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...
Interest paid on loan from directors - At the same time, a huge amount has been borrowed @ 20% interest. No attempt was made to reduce the said borrowing. - No Commercial expediency - claim of interest disallowed - HC
Interest paid on loan from directors - At the same time, a huge amount has been borrowed @ 20% interest. No attempt was made to reduce the said borrowing. - No Commercial expediency - claim of interest disallowed - HC
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