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...
Taxability of transfer fee receipts – it cannot be said that the appellant society violated the model bye laws in the previous year relevant to AY 2004-05 by not adopting the new model bye laws - not taxable on the ground of Principles of mutuality - AT
Taxability of transfer fee receipts – it cannot be said that the appellant society violated the model bye laws in the previous year relevant to AY 2004-05 by not adopting the new model bye laws - not taxable on the ground of Principles of mutuality - AT
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