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 - includability - freight incurred in transportation of goods manufactured - transfer of ownership takes place at the factory gate when the goods are delivered - demand set aside - AT
Valuation - includability - freight incurred in transportation of goods manufactured - transfer of ownership takes place at the factory gate when the goods are delivered - demand set aside - AT
Note: It is a system-generated summary and is for quick reference only.