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...
Undervaluation of goods - Mutuality of interest - interconnected undertaking - Burden of proof - Mere allegation that there was mutuality of interest remained unproved when burden of proof was on Revenue in this regard - AT
Undervaluation of goods - Mutuality of interest - interconnected undertaking - Burden of proof - Mere allegation that there was mutuality of interest remained unproved when burden of proof was on Revenue in this regard - AT
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