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...
Royalty payment to a related person - it is wrong to conclude that that Tarun Mohan being a Director of the respondent was not entitled to enter into an agreement for the transfer of his assets to the company - This ignores the fundamental concept that the assessee being a company incorporated under the Companies Act, 1956 is a separate legal juristic entity - HC
Royalty payment to a related person - it is wrong to conclude that that Tarun Mohan being a Director of the respondent was not entitled to enter into an agreement for the transfer of his assets to the company - This ignores the fundamental concept that the assessee being a company incorporated under the Companies Act, 1956 is a separate legal juristic entity - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
