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...
Valuation of goods - Transaction value and enhancement of the value - the department took recourse to the theory of preponderance of probability to prove the case. The said theory cannot be a substitute for lack of investigation and absence of evidences - AT
Valuation of goods - Transaction value and enhancement of the value - the department took recourse to the theory of preponderance of probability to prove the case. The said theory cannot be a substitute for lack of investigation and absence of evidences - AT
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