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 or Business Consultant - Merger and acquisition services - import of services - Matter remanded back to lower authorities to find out the factual position as to whether the services were received by the appellant or not. - AT
Management or Business Consultant - Merger and acquisition services - import of services - Matter remanded back to lower authorities to find out the factual position as to whether the services were received by the appellant or not. - AT
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