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...
VCES declaration - the designated authority has in the group companies’ case on the very same issue accepted the VCES declaration while in the appellants’ case herein, rejected the same - designated authority directed to re-adjudicate the matter - AT
VCES declaration - the designated authority has in the group companies’ case on the very same issue accepted the VCES declaration while in the appellants’ case herein, rejected the same - designated authority directed to re-adjudicate the matter - AT
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