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...
Dividend income is to be set off against the speculation loss and only the balance amount is to be considered to be speculation loss to be carried forward to be set off only against the speculation profit in subsequent years. - AT
Dividend income is to be set off against the speculation loss and only the balance amount is to be considered to be speculation loss to be carried forward to be set off only against the speculation profit in subsequent years. - AT
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