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 - After sales service - Service Discount in lieu of the Guarantee - there is no evidence on records that any of the after sales money consideration has flown back from the ultimate buyer of the goods to the manufacturer - no demand - AT
Valuation - After sales service - Service Discount in lieu of the Guarantee - there is no evidence on records that any of the after sales money consideration has flown back from the ultimate buyer of the goods to the manufacturer - no demand - AT
Note: It is a system-generated summary and is for quick reference only.
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