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...
Fee for Technical service - Payment for dealings with the Works Department, Abu Dhabi, which included coordinating with the authorities in the said department and handling invoices for the assessee - emittances made by the assessee would not come within the scope of the phrase “fees for technical services” as employed in Section 9(1)(vii) - HC
Fee for Technical service - Payment for dealings with the Works Department, Abu Dhabi, which included coordinating with the authorities in the said department and handling invoices for the assessee - emittances made by the assessee would not come within the scope of the phrase “fees for technical services” as employed in Section 9(1)(vii) - HC
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