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...
Clearing and forwarding agent service or not - providing certain services as Agent to maintain constant liaison with the Railways for the actual placing of coal rakes - There is no role of the appellant in getting the coal cleared from the collieries/ supplier of the coal - Not taxable as C&F agent services - SC
Clearing and forwarding agent service or not - providing certain services as Agent to maintain constant liaison with the Railways for the actual placing of coal rakes - There is no role of the appellant in getting the coal cleared from the collieries/ supplier of the coal - Not taxable as C&F agent services - SC
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