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...
Valuation - physician samples - in the absence of any allegation of price at which the samples were being sold by the assessee to the distributor, the value of said samples has to be sale price of the goods. The fact that distributor further distributed the sample free of cost is irreverent to determine the value of physician samples. - AT
Valuation - physician samples - in the absence of any allegation of price at which the samples were being sold by the assessee to the distributor, the value of said samples has to be sale price of the goods. The fact that distributor further distributed the sample free of cost is irreverent to determine the value of physician samples. - AT
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