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...
Assessable value - the “master charges” are collected for producing specific holograms for their clients and the masters are returned to the clients once the required supplies are made. When the appellant receive these charges as additional consideration for holograms, they are liable for inclusion in the assessable value. - AT
Assessable value - the “master charges” are collected for producing specific holograms for their clients and the masters are returned to the clients once the required supplies are made. When the appellant receive these charges as additional consideration for holograms, they are liable for inclusion in the assessable value. - AT
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