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...
MRP based Valuation – Merely because assessee had cleared detergent bar of 300 gms. at the rate equivalent to the detergent cake of 250 gms., it cannot be said that Section 4A would not come into play - AT
MRP based Valuation – Merely because assessee had cleared detergent bar of 300 gms. at the rate equivalent to the detergent cake of 250 gms., it cannot be said that Section 4A would not come into play - AT
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