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...
Rent-a-car service - abatements - the notification was not mentioned in the ST 3 return - linkage for the consideration to the services rendered previously - apart from ST 3 returns giving details, the appellants provided the invoices along with supporting certificate of such receipt post 1.4.2006 - Demand set aside - AT
Rent-a-car service - abatements - the notification was not mentioned in the ST 3 return - linkage for the consideration to the services rendered previously - apart from ST 3 returns giving details, the appellants provided the invoices along with supporting certificate of such receipt post 1.4.2006 - Demand set aside - AT
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