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...
The idea of “once for all“ payment and “enduring benefit“ are not to be treated as something akin to statutory conditions, nor are the notions of “capital“ or “revenue“ a judicial fetish - HC
The idea of “once for all“ payment and “enduring benefit“ are not to be treated as something akin to statutory conditions, nor are the notions of “capital“ or “revenue“ a judicial fetish - HC
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