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...
Determination of arm's length price (ALP) - rate of commission charged by the assessee from its AEs - It is the assessee who has to substantiate that the price charged is at ALP and not vice versa. The assessee has to face the music if it fails to prove so. - AT
Determination of arm's length price (ALP) - rate of commission charged by the assessee from its AEs - It is the assessee who has to substantiate that the price charged is at ALP and not vice versa. The assessee has to face the music if it fails to prove so. - AT
Note: It is a system-generated summary and is for quick reference only.
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