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...
Rejection of books of accounts - estimation of income from business - The Tribunal upheld the decision of the CIT(A)-NFAC, stating that substantial relief was already granted to the assessee. The Tribunal consistently held that profits should be estimated at 8% on main contracts and 5% on sub-contracts. The decision was based on precedent.
Rejection of books of accounts - estimation of income from business - The Tribunal upheld the decision of the CIT(A)-NFAC, stating that substantial relief was already granted to the assessee. The Tribunal consistently held that profits should be estimated at 8% on main contracts and 5% on sub-contracts. The decision was based on precedent.
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