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...
Classification of service - Appellants are only managing the services and the consultation is only in relation to IT and therefore, in our opinion, the activities are not covered by “Management Consultancy Service” at all - AT
Classification of service - Appellants are only managing the services and the consultation is only in relation to IT and therefore, in our opinion, the activities are not covered by “Management Consultancy Service” at all - AT
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