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...
TP adjustment - disallowance of referral fee - the details and specifics were unavailable despite repeated queries in that regard, ipso facto could not have been a circumstance for the disallowance - HC
TP adjustment - disallowance of referral fee - the details and specifics were unavailable despite repeated queries in that regard, ipso facto could not have been a circumstance for the disallowance - HC
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