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 - royalty/ value of designs, drawings etc. - Only a portion of the lump sum amount attributable to the design cost of product manufactured abroad - only appropriate amount to be included in the value of import - AT
Valuation - royalty/ value of designs, drawings etc. - Only a portion of the lump sum amount attributable to the design cost of product manufactured abroad - only appropriate amount to be included in the value of import - AT
Note: It is a system-generated summary and is for quick reference only.
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