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...
Chargeability to capital gains tax in India - Applicant, a tax resident of Mauritius - transfer of 9,870,912 shares of an Indian Company - applicant is not chargeable to tax in India under Article 13(4) of India-Mauritius Treaty. - AAR
Chargeability to capital gains tax in India - Applicant, a tax resident of Mauritius - transfer of 9,870,912 shares of an Indian Company - applicant is not chargeable to tax in India under Article 13(4) of India-Mauritius Treaty. - AAR
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