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...
Additions against reduction in Gross Profit Rate (GP rate) - rejection of books of accounts - - The assessee has already advanced the reasons for low profit and has submitted the details - Since, there is no specific defects observed in the books of accounts the addition made by the ld. AO on account of the low G.P. we see no reason to sustain the same. - AT
Additions against reduction in Gross Profit Rate (GP rate) - rejection of books of accounts - - The assessee has already advanced the reasons for low profit and has submitted the details - Since, there is no specific defects observed in the books of accounts the addition made by the ld. AO on account of the low G.P. we see no reason to sustain the same. - AT
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