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...
Consideration / fees for technical services - It related to shipment of cargo and their movement across the oceans. The views of the revenue that it amounted to technical service is misconceived. - HC
Consideration / fees for technical services - It related to shipment of cargo and their movement across the oceans. The views of the revenue that it amounted to technical service is misconceived. - HC
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