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 - the amount paid for technical know-how fee and the royalty charges are not to be included in the assessable value of the imported goods, if such payment is for the goods to be manufactured out of the technical know-how, which is transferred by an agreement - AT
Valuation - the amount paid for technical know-how fee and the royalty charges are not to be included in the assessable value of the imported goods, if such payment is for the goods to be manufactured out of the technical know-how, which is transferred by an agreement - AT
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