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...
Imported technical know-how from a foreign entity was not taxable as intellectual property service on reverse charge because the alleged intellectual property was not shown to be recognised under Indian law; the demand was therefore unsustainable and dropped. A composite engineering development arrangement was not taxable as consulting engineering service because the agreement involved joint development, design, detailing, prototype work and production support rather than advice, consultancy or technical assistance simpliciter; the demand was set aside. As both demands failed, issues of limitation, revenue neutrality, interest and penalty did not survive.
Imported technical know-how from a foreign entity was not taxable as intellectual property service on reverse charge because the alleged intellectual property was not shown to be recognised under Indian law; the demand was therefore unsustainable and dropped. A composite engineering development arrangement was not taxable as consulting engineering service because the agreement involved joint development, design, detailing, prototype work and production support rather than advice, consultancy or technical assistance simpliciter; the demand was set aside. As both demands failed, issues of limitation, revenue neutrality, interest and penalty did not survive.
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