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 share capital - transactions were made through banking channel and existence of persons in whose names shares had been issued was shown - burden shifted on the revenue to establish that the investment came from the assessee company itself - HC
Unexplained share capital - transactions were made through banking channel and existence of persons in whose names shares had been issued was shown - burden shifted on the revenue to establish that the investment came from the assessee company itself - HC
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