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...
TPA - payment of royalty - Since the nature of payment was examined by DRP and it was found as revenue expenditure and the direction of the DRP attained finality, this Tribunal is of the considered opinion that the CIT(Appeals) has rightly found that the payment was revenue in nature. - AT
TPA - payment of royalty - Since the nature of payment was examined by DRP and it was found as revenue expenditure and the direction of the DRP attained finality, this Tribunal is of the considered opinion that the CIT(Appeals) has rightly found that the payment was revenue in nature. - AT
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