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...
Omission of the specified domestic transaction provision for related-party expenditure, without a saving clause for pending actions, treats the omitted provision as if it had never existed. Consequently, transfer-pricing cognizance taken under that omitted provision, the reference to the Transfer Pricing Officer, and consequential transfer-pricing proceedings lack validity. Applying this settled position, the Tribunal allowed the taxpayer's grounds and did not sustain the assessment founded on the impugned transfer-pricing reference.
Omission of the specified domestic transaction provision for related-party expenditure, without a saving clause for pending actions, treats the omitted provision as if it had never existed. Consequently, transfer-pricing cognizance taken under that omitted provision, the reference to the Transfer Pricing Officer, and consequential transfer-pricing proceedings lack validity. Applying this settled position, the Tribunal allowed the taxpayer's grounds and did not sustain the assessment founded on the impugned transfer-pricing reference.
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