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...
Valuation - The appellants' claim that they have paid the VAT on 80% of the value may possibly be an indicator of the value of goods involved but it cannot be accepted on the face value in the absence of any documentary evidence - AT
Valuation - The appellants' claim that they have paid the VAT on 80% of the value may possibly be an indicator of the value of goods involved but it cannot be accepted on the face value in the absence of any documentary evidence - AT
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