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...
Insurance services - revenue alleged that the assessee had received the amount - appellant submits that the basis on which Revenue stated that they received payment from PACL, Nayanangal. is not disclosed to them - revenue failed to provide evidence - demand set aside. - AT
Insurance services - revenue alleged that the assessee had received the amount - appellant submits that the basis on which Revenue stated that they received payment from PACL, Nayanangal. is not disclosed to them - revenue failed to provide evidence - demand set aside. - AT
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