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 – Computation of ALP – Advances made to overseas subsidiaries – The differences are so fundamental that these differences, to use the phraseology employed in Rule 10 B (1)(a)(ii), “could materially affect the price in the open market“ - the application of LIBOR plus rate or, for that purpose, any bank rate will be inappropriate to this case. - AT
Transfer pricing adjustment – Computation of ALP – Advances made to overseas subsidiaries – The differences are so fundamental that these differences, to use the phraseology employed in Rule 10 B (1)(a)(ii), “could materially affect the price in the open market“ - the application of LIBOR plus rate or, for that purpose, any bank rate will be inappropriate to this case. - AT
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