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...
Purchase of Technical know-how - Covered under section 9(l)(vi) of Income Tax Act, 1961 and treated as royalty - The Seller had sold, assigned, conveyed and transferred to assessee its entire right, title, interest and ownership in the asset - not taxable in view of DTAA - AT
Purchase of Technical know-how - Covered under section 9(l)(vi) of Income Tax Act, 1961 and treated as royalty - The Seller had sold, assigned, conveyed and transferred to assessee its entire right, title, interest and ownership in the asset - not taxable in view of DTAA - AT
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