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...
Exemption u/s 10(26AAA) - Sikkimese - the assessee though is not a Sikkimese and is name is not appearing in the Register of Sikkim but as per the residential certificate issued by the District Collector, East District, Gangtok, he is found to be domiciled in the state of Sikkim on or before 26th April, 1975 and, therefore, assessee is well covered by the decision of the Hon’ble Supreme Court and thus, is entitled to exemption u/s 10(26AAA) - AT
Exemption u/s 10(26AAA) - Sikkimese - the assessee though is not a Sikkimese and is name is not appearing in the Register of Sikkim but as per the residential certificate issued by the District Collector, East District, Gangtok, he is found to be domiciled in the state of Sikkim on or before 26th April, 1975 and, therefore, assessee is well covered by the decision of the Hon’ble Supreme Court and thus, is entitled to exemption u/s 10(26AAA) - AT
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