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...
Steamer Agent Service - services were rendered to a shipping line and payment was received from shipping line. That being the case, prima facie, the demand under the head for steamer agent’s service is not maintainable - AT
Steamer Agent Service - services were rendered to a shipping line and payment was received from shipping line. That being the case, prima facie, the demand under the head for steamer agent’s service is not maintainable - AT
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