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...
Transfer pricing adjustment - Offshore activities – The fabrication and supplies are made by the third parties outside India to the assessee and the revenue is not taxing the profits of these third parties - matter remanded back for verification of facts - AT
Transfer pricing adjustment - Offshore activities – The fabrication and supplies are made by the third parties outside India to the assessee and the revenue is not taxing the profits of these third parties - matter remanded back for verification of facts - AT
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