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...
Neither the freight nor the inspection charges are paid by the appellant company for any services rendered by these company in India, and nor the payments are made to these parties in India, and therefore, by no imagination either the provisions of section 194C or section 195 are applicable - AT
Neither the freight nor the inspection charges are paid by the appellant company for any services rendered by these company in India, and nor the payments are made to these parties in India, and therefore, by no imagination either the provisions of section 194C or section 195 are applicable - AT
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