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...
Transfer pricing adjustment - interest free advances granted by the assessee to its Indian AE - base erosion theory - Tribunal rejected the the contention of the assessee that, in principle, no arm’s length price adjustments can be made in respect of the interest free advances granted by the assessee to its Indian AE, i.e. Datex Ohmeda India Pvt Ltd. - AT
Transfer pricing adjustment - interest free advances granted by the assessee to its Indian AE - base erosion theory - Tribunal rejected the the contention of the assessee that, in principle, no arm’s length price adjustments can be made in respect of the interest free advances granted by the assessee to its Indian AE, i.e. Datex Ohmeda India Pvt Ltd. - AT
Note: It is a system-generated summary and is for quick reference only.