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...
Notional interest - When the parties have agreed not to charge the interest, as per the condition laid down in the MoU i.e. “if the remittance is within the less than two months“, then the AO cannot compel to do so - HC
Notional interest - When the parties have agreed not to charge the interest, as per the condition laid down in the MoU i.e. “if the remittance is within the less than two months“, then the AO cannot compel to do so - HC
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