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...
Disallowance u/s 40A(3) - Cash payment - Section 40A(3) is not applicable when the net profit rate was applied by the AO and once a net profit rate is applied the expenses are deemed to be considered while applying the net profit rate. - HC
Disallowance u/s 40A(3) - Cash payment - Section 40A(3) is not applicable when the net profit rate was applied by the AO and once a net profit rate is applied the expenses are deemed to be considered while applying the net profit rate. - HC
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