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...
Management, Maintenance or Repair Services – assessee had been awarded a contract of laying pipelines and also pumping operation, maintenance and repair of such pipelines along with pumping machinery for supply of water to various district and taluka places - stay granted partly - AT
Management, Maintenance or Repair Services – assessee had been awarded a contract of laying pipelines and also pumping operation, maintenance and repair of such pipelines along with pumping machinery for supply of water to various district and taluka places - stay granted partly - AT
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