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...
Denial of refund claim - marketing support services - Service provided and consumed in India - recipient of the services is not Indian customer of the foreign supplier but it is the foreign principal qualifies to be an export of services - AT
Denial of refund claim - marketing support services - Service provided and consumed in India - recipient of the services is not Indian customer of the foreign supplier but it is the foreign principal qualifies to be an export of services - AT
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